By: Augusto Nicolás Mancinelli

Argentina’s new Law 27,430 introduces a new taxable event: a Value Added Tax (hereinafter VAT) applicable to the importation of “digital services” rendered by a non-resident to a resident individual or entity when the effective use or exploitation of the service is carried out inside Argentina.

An earlier regulation, Decree 354/2018 of April 23, 2018, a deficient attempt to regulate the VAT applicable on digital services, was recently repealed.

According to the current wording of the VAT Law and its Regulatory Decree, VAT applicable to the importation of digital services has the characteristics that are detailed below.


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Guest post from our friends at Bergstein Abogados

Uruguay requires online companies incorporated abroad, with no presence in Uruguay, to pay taxes in Uruguay whenever their clients are located within Uruguayan territory. Online services providers (such as Netflix and Spotify) are subject to VAT at the rate of 22 percent, plus Non-Residents Income Tax (so-called IRNR) at the rate of 12 percent, both assessed over the sales price. Online services intermediaries (such as Airbnb) are subject to the same taxes, except that IRNR is assessed only over 50 percent of their sales where one of the parties of the ultimate transaction (the supplier or end-user) is based abroad.

In May this year, Uruguay’s Executive Branch issued a regulatory decree, summarized below, clarifying aspects of the tax law; and a few days ago, the Tax Office issued a special resolution spelling out certain implementation details.
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On August 1st, 2017, it was published the Executive Decree no. 9,115/2017, which internalized the Convention for the Avoidance of Double Taxation between Brazil and Russia (“Brazil-Russia Treaty” or “Convention”), signed in Brasilia on November 22nd, 2004. We have focused on the most relevant points, considering most usual queries of taxpayers.

According to article 2 of the Convention, the rules to avoid double taxation shall apply to the Brazilian income  tax of individuals and corporations and the Russian tax on profits of organizations and Russian income tax on individuals. There is no mention regarding Brazilian Social Contribution on Net Profits (CSLL), but it can be interpreted that the aforementioned contribution is covered by the Brazil-Russia Treaty by virtue of section 11 of Law no. 13,202/2015.

(Portuguese language full content below)
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