2014阿根廷商税指南_37页-1mb

Summary of "Investing in Argentina"

Core Content

This document provides an overview of the economic and political landscape of Argentina and outlines various investment opportunities and legal considerations for foreign investors. It also includes data on Latin America's economic performance and tax implications for different investment methods.

Main Points

I. Latin America in the World Economy

• Economic Growth Projections: For 2013, Latin America and the Caribbean are expected to grow by 3%, similar to 2012. The North is projected to grow at 2.5% (UN), 2.3% (OECD), and 2.5% (IMF), while the South is projected to grow at 5.6% (UN), 6.7% (OECD), and 6.2% (IMF).
• Trade Dynamics: Exports from the region are expected to grow by 4.0% in 2013, up from 1.5% in 2012. Imports are projected to increase by 6%.
• GDP Evolution: Argentina's GDP growth has been relatively strong compared to other Latin American countries in recent years, with a growth of 4.5% in 2013.
• Trading Blocks: The region includes several trading blocks such as CARICOM, NAFTA, ANDEAN COMMUNITY, and MERCOSUR, which influence economic integration and trade policies.

II. Argentina: Political and Economic Overview

• Political Situation: President Cristina Kirchner faced weakened political position after the 2013 October elections and was out of action for five weeks due to health reasons. The new cabinet includes a progressive economist, Axel Kicillof, as Minister of Economics, and the president is showing support for a potential coalition candidate in 2015.
• Economic Situation: Argentina's economic growth has slowed in recent years, and it has lost ground relative to its regional peers. The investment boom following the 2015 elections is expected to boost economic growth. Key sectors include energy, automotive, agribusiness, infrastructure, and financial services.
• Economic Trends: The middle class in the region is growing, leading to increased demand for goods and services. Argentina's economy is seen as having potential in underdeveloped sectors, particularly in infrastructure and energy.

III. Legal Environment for Business in Argentina

• Foreign Investment Regulations: Argentina has established regulations to promote foreign investment, ensuring equal treatment of domestic and foreign investors.
• Investment Restrictions: There are no restrictions on foreign investment in any economic activity, and no local participation requirements are mandated.
• Employment of Foreigners: No restrictions on employing foreigners, provided they comply with immigration laws.
• Corporate Forms: Argentina recognizes various forms of business organization, including companies.
• Timeline for Setting Up a Corporation: The process involves registering the foreign company with the Superintendentage of Corporations, which may take 1 to 3 months.

IV. Investment Methods and Tax Impacts

• Acquisition of Business: Two main methods are available: acquiring local assets or local stock. Tax implications vary between these methods.
• Taxation Overview:
  • Corporate Income Tax: 35%
  • Tax on Minimum Presumed Income (TOMPI): 1% on assets
  • VAT: 21% or 10.5%
  • Additional VAT: 20% or 10%
  • Income Tax: 6%
  • Turnover Tax: 0% to 2.25%
  • Dividend Withholding: 0% to 35% (ET) + 10%
  • Royalty Withholding: 12.25% to 31.5%
  • Interest Withholding: 15.05% to 35%
• Transfer Pricing: Argentina follows OECD rules and uses methods such as CUP, Cost Plus, Resale Price, Profit Split, and TNMM. Transactions with tax haven affiliates are presumed not to be arm's length.
• Exchange Control: There are strict procedures for importing and exporting, including mandatory deposits on foreign loans and investments (up to 30%). There are also deadlines for converting foreign currency earnings into local currency.

Key Investment Opportunities

• Automotive Industry: High local know-how and full capacity utilization, with opportunities for promotion regimes and access to Mercosur markets.
• Agribusiness: Mature and highly developed sector with access to international financing and growing demand. Opportunities include exporting business models to less developed markets and incorporating industrial technology.
• Infrastructure: Significant need for investment in rail transport and underground infrastructure. Opportunities for joint ventures with foreign companies and technology transfer.
• Financial Industry: Opportunities for expansion and investment in underdeveloped local entities, with potential for regional growth.
• Oil & Gas: Vaca Muerta Shale is a key opportunity. Potential for joint ventures with junior NOCs and NOCs for offshore exploration. Specific M&A opportunities exist.
• Power Industry: Opportunities in hydroelectric and wind energy due to lack of investment. Possibilities for tariff negotiation in exchange for investment.

Advantages of Investing in Argentina

• High Educational Level: Argentina has a well-educated workforce.
• Low Entry Threshold: Foreign investors can enter the market with relatively low barriers.
• Economic Growth Expectations: The region is expected to grow, offering investment opportunities.
• Infrastructure Potential: Despite being underdeveloped, Argentina's infrastructure is considered one of the best in the region.

Contact Information

• Daniel Varde (FAS Lead Partner):
  Email: dvarde@deloitte.com
  Tel: 4321-2756

• Marcos Bazaar (M&A Partner):
  Email: mgbazan@deloitte.com
  Tel: 4321-2774

• Ricardo Ferreyra (M&A Tax Partner):
  Email: rferreyra @deloitte.com
  Tel: 4321-3017

• Deloitte:
  Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited and its member firms. For more details, visit www.deloitte.com/about.