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Text Ordered by Decree 649/97 (B.O. 06/08/97), Annex I, with subsequent amendments.

See Background

PART I

GENERAL PROVISIONS

SUJECT AND OBJECT OF IMPEST

Article 1 - All gains obtained by human, legal or other persons specified in this law are reached by the emergency tax provided for in this rule.

Indivisible successions are contributors under article 33.

Subjects referred to in the preceding paragraphs, resident in the country, bear in mind the totality of their profits obtained in the country or abroad, and may, as a payment of the tax of this law, be computed the amounts actually paid for by analogous taxes, on their activities abroad, to the limit of the increase in the tax obligation arising from the incorporation of the gain obtained abroad.

Non-residents tax exclusively on their gains from Argentine sources, as provided for in Title V and supplementary rules of this law.

(Article replaced by Article 1 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Art. 2° - For the purposes of this law, they are profits, without prejudice to the provisions of each category and even if they are not indicated in them:

1) yields, incomes or enrichments susceptible to a periodicity that implies the permanence of the source that produces them and their empowerment.

(2) the returns, incomes, profits or enrichments that meet or not the conditions of the preceding paragraph, obtained by those responsible under article 69 and all that derive from other societies or from single-person enterprises or enterprises, except that, not from the contributors covered by article 69, the activities specified in article 79 (f) and (g) shall be carried out, and these shall not be supplemented by the previous commercial exploitation,

3) the results from the disposal of movable goods amortizable, whatever the subject obtains them.

4) the results derived from the disposal of shares, representative values and certificates of deposit of shares and other values, quotas and social participations .including shares of common funds of investment and certificates of participation of financial trusts and any other right on trusts and similar contracts,, digital currencies, Titles, bonds and other values, whatever the subject that obtains them.

5) the results derived from the disposal of properties and the transfer of rights on properties, regardless of the subject obtaining them.

(Article replaced by Article 2 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Art. 3o - For the purposes set forth in this law the sale, permute, change, expropriation, contribution to societies and, in general, any act of disposition by which the domain is transmitted in onerous title.

In the case of property, the disposal or acquisition, as appropriate, shall be deemed to be configured when the sale ticket or other similar commitment is mediated, provided that the possession or, if not, at the time of this act, is given or obtained according to the case posesión the possession or, in its absence, at the time of this act, even when the translative writing of domain has not been held. (Paragraph replaced by art. 3rd of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Art. 4o - For all purposes of this law, in the case of taxpayers who receive property by inheritance, legacy or donation, the tax value of such assets shall be considered as the value of acquisition for their predecessor to the date of entry to their property and as the date of acquisition of the latter.

In the event that the value of the said value cannot be determined, the value of the position of the asset to the date of the latter transmission shall be considered as value of acquisition in the manner determined by the regulation. (Paragraph replaced by art. 4° of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

^(*) (Note: - With regard to the allusions made by law concerning the updating of various concepts, the provisions of the Act on Convertibility No. 23,928 and its regulatory and complementary standards should be set out in this regard. )

Source

Art. 5o - In general, and without prejudice to the special provisions of the following articles, the proceeds of Argentine sources are those that come from property located, placed or used economically in the Republic, of the realization in the territory of the Nation of any act or activity that may produce profits, or of events occurring within the limit of the same, without taking into account the nationality, domicile or residence of the holder or of the parties involved in the operations, or the place of the contracts.

Art. 6o - The proceeds from secured credits with real rights constituted on property located in the national territory shall be considered as gains from Argentine source. Where the guarantee has been made up of goods located abroad, the provisions of the preceding article shall apply.

Art. 7o - With the exception of the following paragraph, profits from the possession and disposal of shares, quotas and social shares .including shares of funds Common investment and certificates of participation of financial trusts and any other right on trusts and similar contracts ., digital currencies, Titles, bonds and other values, shall be considered entirely of Argentine source when the issuer is established in Argentina. The representative values or certificates of deposit of shares and other values shall be considered as an Argentine source when the issuer of the actions and the other values is domiciled, constituted or based in the Argentine Republic, either the issuing entity of the certificates, the place of issue of the latter or the place of deposit of such actions and other values.

(Article replaced by Article 5 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Art. ... - The results originated by emerging rights and obligations of derivative instruments and/or contracts shall be considered as gains from Argentine sources, when the risk assumed is located in the territory of the Argentine Republic, a location that should be considered to be set up if the party obtaining such results is a resident in the country or a permanent establishment covered by article 69 (b). (Expression stable stability is replaced by permanent enlightenment, by art. 79 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

However, when the different components of one of the above-mentioned instruments or a set of them that are linked, indicate that the instrument or the set of instruments do not express the real economic intention of the parties, the determination of the location of the source shall be carried out in accordance with the principles applicable to the nature of the producer source that corresponds to consider in accordance with the principle of economic reality, in which case the treatments provided for by this law shall apply for the results originated by the same.

(Convention of Article 7 by Act No. 25.063, Title III, art.4°, subparagraph (a). - Watch: From 31/12/98.)

Art. 8o - The profits from the export of goods produced, manufactured, treated or purchased in the country are entirely of Argentinean source, including the transfer of such goods through subsidiaries, branches, representatives, procurement agents or other intermediaries of persons or entities abroad.

The net profit shall be determined by deducting from the sale price the cost of such goods, the costs of transport and insurance to the duty station, the commission and sales expenses and the expenses incurred in the Argentine Republic, as soon as they are necessary to obtain the tax revenue.

For their part, the profits obtained by exporters from abroad by the simple introduction of their products in the Argentine Republic are of foreign source.

Where the operations referred to in this article are carried out with persons or entities involved and their prices and conditions do not conform to market practices between independent parties, they shall be adjusted in accordance with article 15 of this Act.

Moreover, the transactions covered by this article with human, legal, property and other entities, domiciled, constituted or located in non-cooperative or low- and non-tax jurisdictions shall not be considered in accordance with the practices or normal market prices between independent parties. (Paragraph replaced by Article 6 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

In cases where, in accordance with the above provisions, the import or export of goods in respect of which the international price of público public and notorious knowledge de can be established through transparent markets, trade exchanges or similar, it shall be, except evidence to the contrary, to use such prices for the purpose of determining the net gain of Argentine source.

In the case of operations other than those specified in the preceding paragraph, between independent parties, the taxpayer .exporter or importer Público shall provide the Federal Public Income Administration with the information available therein for the purpose of establishing that the declared prices are reasonably in line with those of the market, including the allocation of costs, profit margins and other data that such agency considers necessary for the control of such operations, provided that the amount carried out annually

(Article replaced by Article 1 of the Act No. 25.784B.O. 22/10/2003. - Watch: From the day of publication in B.O.)

Art. 9o - It is presumed, without admitting evidence to the contrary, that the companies that are not incorporated in the country that deal with the transport business between the Republic and foreign countries, obtain for that activity net gains of Argentine source, equal to TEN per SCIENTO (10 %) of the gross amount of the freights by passages and cargoes corresponding to those transports.

Likewise, it is presumed, without admitting evidence to the contrary, that the TEN BY SCIENTO (10 %) of the sums paid by companies based or constituted in the country to foreign shipowners by charters on time or for travel, constitute net gains of Argentine source.

The presumptions referred to in the preceding paragraphs shall not apply in the case of enterprises established in countries with which, under international conventions or treaties, tax exemption had been established or established.

In the case of companies not incorporated in the country that deal in the container business for the transport in the Republic or from it to foreign countries, it is presumed, without admitting evidence to the contrary, that they obtain for that activity net gains of Argentine source equal to the VEINTE BY CIENTO (20 %) of the gross revenue originated by that concept.

The agents or representatives in the Republic, of the companies mentioned in this article, shall be jointly responsible for the payment of the tax.

The profits obtained by companies established or based in the country dealing with the businesses referred to in the preceding paragraphs are considered entirely as an Argentinean source, with the exception of the places in which they operate.

Art. 10 - It is presumed that international news agencies that, through a retribution, provide them to people or entities resident in the country, obtain for that activity net gains of Argentine source equal to TEN BY SCIENTO (10 %) of the gross retribution, have or not agency or branch in the Republic.

Please make it possible for the Executive Power to generally set percentages below that set out in the previous paragraph when the application of the latter could result in results not in line with reality.

Art. 11 - Income from insurance or reinsurance operations that cover risks in the Republic or refer to persons who have resided in the country at the time of the conclusion of the contract are of Argentina.

In the case of cessions to foreign companies -areinsurance and/or retrocessions - it is presumed, without admitting proof to the contrary, that the TEN BY SCIENTO (10 %) of the amount of the yielded premiums, net of cancellations, constitutes net gain of Argentine source.

Art. 12 - Remuneration or salaries of members of directories, councils or other agencies - of companies or entities constituted or domiciled in the country - which operate abroad shall be considered as gains of Argentine source.

In addition, the fees or other remuneration arising from technical, financial or other advice provided from abroad shall be considered as an Argentine source.

Art. 13 - It is presumed, without admitting evidence to the contrary, that constitutes a net gain of Argentinean source fifty percent (50%) of the price paid to producers, distributors or intermediaries for the exploitation in the country of foreign films, radio and television broadcasts issued from the outside and all other operation that involves the projection, reproduction, transmission or diffusion of images and/or sounds from the outside regardless of the means used.

The above provisions will also apply when the price is paid in, form of royalty or similar concept.

(Article replaced by Article 7 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Art. ... - Indirect disposal of property located in the national territory. Argentine source gains are considered as those obtained by non-residents in the country from the disposal of shares, quotas, social participations, Titles convertible in social actions or rights, or any other representative right of the capital or heritage of a legal person, fund, trust or equivalent figure, permanent establishment, property of affectation or any other entity, which is constituted, domiciled or located abroad, when the following conditions are met:

(a) The market value of the shares, shares, shares, shares, titles or rights that such alien has in the constituted, domiciled or located outside, at the time of sale or in any of the twelve (12) months prior to the disposal, comes at least thirty per cent (30%) of the value of one (1) or more of the following assets of which it is owned directly or through other entities:

(i) actions, rights, quotas or other titles of participation in the ownership, control or profits of a company, fund, trust or other entity incorporated in the Argentine Republic;

(ii) permanent establishments in the Argentine Republic belonging to a person or non-resident entity in the country; or

(iii) Other property of any kind located in the Argentine Republic or rights thereon.

For the purposes of this subparagraph, the country ' s assets shall be assessed in accordance with their current value in square.

(b) The actions, participations, quotas, titles or rights alienated . themselves or in conjunction with entities on which it possesses control or connection, with the spouse, with the convivant or with other taxpayers united by bonds of kinship, in an ascending line, descending or collateral, by consanguinity or affinity, up to the third degree inclusive - represent, at the time of sale or in any of the preceding one hundred (12)

The gain of Argentine source referred to in this article is that determined in accordance with the provisions of the second section of the fourth paragraph of the fourth article without an aggregate number following article 90 but only in the proportion of the share of the goods in the country in the value of the alienated actions.

The provisions of this article shall not be applicable when it is demonstrated that these are transfers carried out within the same economic set and the requirements established by the regulation are met.

(Article s/n incorporated after Article 13 by Article 8 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Art. 14 - The branches and other stable establishments of companies, persons or entities of the foreigner shall carry out their accounting records separately from their matrices and other branches and other stable establishments or subsidiaries (subsidiaries) of these, making in their case the necessary corrections to determine their tax result of the Argentine source.

In the absence of sufficient accounting or when the same does not reflect exactly the net gain of Argentinean source, the FEDERAL ADMINISTRATION OF PUBLIC INCOME, autarchical entity within the scope of the MINISTERY OF ECONOMY AND ARTWS AND SERVICES PUBLICOS, may consider that the entities of the country and the outside referred to in the previous paragraph form an economic unit and determine the corresponding net profit.

Transactions between a permanent establishment, referred to in the article without an aggregate number following article 16, or a corporation or trust included in article 49, subparagraphs (a), (b), (c) and (d), respectively, with persons or related entities constituted, domiciled or located abroad, shall be considered, for all purposes, as concluded between independent parties when their benefits and conditions are in accordance with the normal practices of the market between the 88 mtes. Where such benefits and conditions do not conform to market practices among independent entities, they will be adjusted in accordance with Article 15. (Third paragraph replaced by article 9 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

To the extent that the permanent establishment in the country carries out activities that directly or indirectly permit the parenting house or any foreign-related subject to earning income, the appropriate party shall be assigned to that party in accordance with its contribution and in accordance with the methods set out in that article 15. (Paragraph incorporated by art. 9° of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

In the case of financial entities operating in the country, the provisions provided for in article 15 shall be applied for the amounts paid or credited to their parent, co-filial or co-responsive or other entities or associated entities constituted, domiciled or located abroad, for interest, commissions and any other payment or accreditation originated in transactions made with them, where the amounts are not in conformity with the normal agreed market agreements. The FEDERAL ADMINISTRATION OF PUBLIC INCOME, an autonomous entity within the Ministry of Economy and Public Works and Services, may, if necessary, require the information of the Central Bank of the Argentine Republic that it considers necessary for these purposes.

(Article replaced by Act No. 25,239, Title I, art.1°, subparagraph (b). - Watch: From 31/12/99, the exercises starting from that date will take effect. )

Art. 15 - When, by the type of operations or by the modalities of organization of the companies, the gains of Argentine source cannot be established accurately, the Federal Public Income Administration may determine the net profit subject to the tax through averages, indices or coefficients that to this end establish based on results obtained by independent companies dedicated to activities of equal or similar characteristics.

Transactions that permanent establishments domiciled or located in the country or subject to article 49, paragraph 1 (a), (b), (c) and (d), shall be carried out with human or legal persons, assets of affectation, establishments, trusts and equivalent figures, domiciled, constituted or located in non-cooperative or low- or no-tax jurisdictions shall not be considered in accordance with normal market or market prices.

For the purpose of determining the prices of transactions referred to in the preceding article, the most appropriate methods will be used in accordance with the type of transaction. The restriction set out in article 101 of the Act 11,683, which was ordained in 1998 and its amendments, shall not apply to the information referred to to third parties that may be necessary for the determination of such prices, when it must be opposed as evidence in cases that deal with administrative or judicial headquarters.

The capital societies covered by article 69, paragraph 1 (a), the permanent establishments included in the first article, as set out in article 16, and the other subjects provided for in article 49, paragraph 1 (b), (c) and (d), other than those referred to in the third paragraph of the previous article, are subject to the same conditions as those relating to transactions with their foreign affiliates, branches, permanent establishments or other entities.

For the purposes set out in the third paragraph, the methods of comparable prices between independent parties, of resale prices fixed between independent parties, of more profitable cost, of division of profits and of net margin of the transaction shall apply. The regulation shall be responsible for establishing the form of application of the above-mentioned methods, as well as for establishing others which, for identical purposes and for the particular nature and circumstances of transactions, so merit it.

In the case of import or export operations of goods involving an international intermediary other than, respectively, the exporter in origin or the importer in destination of the goods, shall be credited according to what establishes the regulation— that the remuneration it obtains relates to the risks assumed, the functions exercised and the assets involved in the operation, provided that one of the following conditions is verified:

(a) that the international intermediary is linked to the local subject in the terms of the article incorporated after article 15;

(b) that the international intermediary is not covered by the preceding subparagraph, but the exporter in origin or the importer in destination is linked to the respective local subject in the terms of the article incorporated after article 15.

In the case of export operations of goods with quotations involving an international intermediary who meets any of the conditions referred to in the sixth paragraph of this article, or is located, constituted, based or domiciled in a non-cooperative jurisdiction or low or no taxation, the taxpayers shall, without prejudice to what is required in the preceding paragraph, carry out the registration of the contracts held for the purpose of such transactions If the corresponding registration is not carried out in the terms in which the regulation is established or to be carried out but not to be fulfilled, the Argentine export source income shall be determined by considering the value of the price of the good of the day of the load of the goods .any means of transport,, including the comparability adjustments that may correspond, without considering the price to which it would have been agreed with the international intermediary. The Federal Public Income Administration may extend the registration obligation to other export transactions of listed goods.

The subjects covered by the provisions of this article shall submit special annual affidavits, in accordance with the provisions of the regulation, which shall contain such information as may be necessary to analyse, select and proceed to the verification of the agreed prices, as well as information of an international nature without prejudice to the realization, where appropriate, by the Federal Public Income Administration, of simultaneous or joint inspections with the tax authorities designated by the States.

The regulation shall also establish the minimum income limit invoiced in the fiscal period and the minimum amount of transactions subject to the transfer price analysis, to be reached by the obligation of the preceding paragraph.

In all cases of import or export of goods involving an international intermediary, taxpayers shall accompany the documentation that will help to establish whether the provisions of paragraphs 6 to 8 of this article are applicable.

The regulation shall also provide the information to be provided by taxpayers in respect of the operations covered by paragraphs 6 to 8 of this article.

(Article replaced by Article 10 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Art. ... - For the purposes set forth in this law, the linkage shall be set up when a subject and person or other type of entity or establishments, trusts or equivalent figures, with whom the person conducts transactions, are directly or indirectly subject to the direction or control of the same human or legal persons or such entities, whether by their participation in the capital, their degree of aggressions, their functional influences or of any other kind, contractual or otherwise, have the power to define.

The regulation may establish the cases of linkage to those referred to in the preceding paragraph.

(Article s/n incorporated after art. 15, replaced by art. 11 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

(Note Infoleg: by art. 7° from Decree No. 279/2018 B.O. 9/4/2018 states that until the second article is regulated without an aggregate number following article 15 of the Law on the Tax on Livestock, a text ordered in 1997 and its amendments, to determine whether a jurisdiction is ”cooperante” will be verified if it is included in the current list published by the FEDERAL ADMINISTRATION OF PUBLIC INCOME under Decree No. 589 of May 2013. Watch: the day after your publication in the Official Gazette)

Art. ... - Non-cooperative jurisdictions. For all purposes provided for in this law, any reference made to non-cooperative subjurisdictions should be understood to refer to those countries or jurisdictions that do not have a tax information exchange agreement with the Argentine Republic or an agreement to avoid double international imposition with a broad information exchange clause.

Countries that, having an agreement with the scope defined in the preceding paragraph, do not effectively comply with the exchange of information shall also be considered as non-cooperative.

The agreements and agreements referred to in this article shall comply with the international standards of transparency and exchange of information in tax matters to which the Argentine Republic has committed itself.

The national executive branch shall draw up a list of non-cooperative jurisdictions based on the criterion contained in this article.

(Article s/n incorporated following the article without added number following article 15, by art. 12 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Art. ... - Jurisdictions of low or no taxation. For all purposes provided for in this law, any reference made to low- or no-cost taxation, shall be understood to refer to those countries, domains, jurisdictions, territories, associated states or special tax regimes that establish a maximum taxation to the business income of less than sixty per cent (60%) of the liquota provided for in article 69 (a) of this Act.

(Article s/n incorporated following the article without added number following article 15, by art. 12 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Art. 16 - In addition to the provisions of article 5, earnings from personal work are also considered as an Argentine source when they consist of salaries or other remuneration that the State pays to its official representatives abroad or to other persons entrusted with the performance of functions outside the country.

Art. ... - Permanent establishment. For the purposes of this law the term "permanent self-establishment" means a fixed place of business through which a subject of the outside performs all or part of his activity.

In addition, the term permanent enlightenment is particularly understood:

(a) a management or administration headquarters;

(b) one branch;

(c) one office;

(d) a factory;

(e) a workshop;

(f) a mine, an oil or gas well, a quarry or any other place related to the exploration, exploitation or extraction of natural resources including fishing.

The term permanent enlightenment also includes:

(a) a work, a construction, a project of assembly or of installation or supervision related to them, when such works, projects or activities take place in the territory of the Nation for a period exceeding six (6) months.

When the foreign resident subcontracts with other related companies the activities mentioned in the preceding paragraph, the days used by subcontractors in the development of these activities shall, if any, be added to the computation of the aforementioned period.

(b) the provision of services by a foreigner, including the services of consultants, either directly or through their employees or staff recruited by the company for that purpose, but only in the event that such activities continue in the territory of the Nation for a period or periods that exceed six (6) months, within a period of twelve (12) months.

For the purposes of computing the deadlines referred to in subparagraphs (a) and (b) of the third paragraph, the activities carried out by subjects with which there is any link in the terms of the first article without an aggregate number following the 15 of this law shall be considered jointly, provided that the activities of both companies are identical or similar.

The term " permanent establishment " does not include the following activities insofar as they possess an auxiliary or preparatory character:

(a) The use of facilities for the sole purpose of storing or exposing goods or goods belonging to the company;

(b) the maintenance of a deposit of goods or goods belonging to the company for the sole purpose of storing or exposing them;

(c) the maintenance of a deposit of goods or goods belonging to the company for the sole purpose of being transformed by another company;

(d) Maintenance of a fixed place of business for the sole purpose of buying goods or goods or collecting information for the company;

(e) the maintenance of a fixed place of business for the sole purpose of undertaking for the company any other activity with such character;

(f) The maintenance of a fixed place of business for the sole purpose of undertaking any combination of the activities referred to in subparagraphs (a) to (e), provided that the whole of the activity of the fixed place of business resulting from that combination preserves its auxiliary or preparatory character.

Notwithstanding the provisions of the preceding paragraphs, it is considered that there is a permanent establishment when a subject acts in the national territory on the behalf of a human or legal person, entity or property of the outsider and that subject:

(a) possesses and habitually exercises powers that empower him to conclude contracts on behalf of the person concerned, whether human or legal, entity or foreign property, or to play a role of significance leading to the conclusion of such contracts;

(b) To maintain in the country a deposit of goods or goods from which it regularly delivers goods or goods on behalf of the foreigner;

(c) Takes risks that correspond to the foreign resident;

(d) act subject to detailed instructions or the general control of the outsider;

(e) engages in activities that are economically owned by the resident abroad rather than his own activities; or

(f) Perceive its remuneration irrespective of the outcome of its activities.

It will not be considered that a subject has a permanent establishment for the mere conduct of business in the country through brokers, commissioners or any other intermediary who enjoys an independent situation, provided that they act in the usual course of their own business and in their business or financial relations with the company, the conditions do not differ from those generally agreed by independent agents. However, when a subject acts entirely or primarily on behalf of a human or legal person, entity or foreign property, or of several of these interlinked, that subject shall not be considered an independent agent within the meaning of this paragraph with respect to such enterprises.

(Article s/n incorporated after art. 16, by art. 13 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

GANANCIA NETA AND GANANCIA NETA SUJETA TO IMPEST

Art. 17 - In order to establish the net profit, the expenses necessary to obtain the net gain shall be deducted from the gross profit or, if any, to maintain and retain the source, the deduction of which admits this law, in the manner provided by it.

In order to establish the net profit subject to tax, the net profits of the first, second, third and fourth categories shall be subtracted from the deductions authorized by Article 23.

In no case shall the expenses associated with profits exempt or not covered by this tax be deductible.

When the net result of luxury, personal and similar investments, established in accordance with the provisions of this law, comes to a loss, will not be computed for the purposes of the tax.

YEAR FISCAL AND IMPUTATION OF GANANCIES AND

Art. 18 - The fiscal year begins on 1 January and ends on 31 December.

Taxpayers will charge their profits to the fiscal year, according to the following rules:

(a) The profits obtained as owner of civil, commercial, industrial, agricultural or mining companies or as partners of them will be charged to the fiscal year in which the corresponding annual year is complete.

The profits set out in article 49 are considered from the fiscal year in which the annual period in which they are accrued is completed.

When operations are not accounted for, the exercise will coincide with the fiscal year, except for other provisions of the IMPOSTITIVE GENERAL DIRECTION, which is entitled to set periods of closure in response to the nature of the exploitation or other special situations.

The proceeds of the exercise are considered to be gains. However, the profits may be imputed at the time of the respective demand, when the profits originate in the sale of goods made with periods of financing exceeding ten (10) months, in which case the option shall be maintained at the end of five (5) years and its exercise shall be externalized through the procedure determined by the regulation. The criterion of imputation previously authorized may also apply in other cases expressly provided for by law or its regulatory decree. The share or profit dividends distributed by the subjects of Article 69 and the interests or returns of Titles, bonds, shares of common investment funds and other values shall be charged in the exercise in which they have been: (i) made available or paid, which occurs first; or (ii) capitalized, provided that the values preview interest payments or returns within a period of up to one year. (Fourth paragraph replaced by article 14 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

In respect of values that provide for payment periods of more than one year, the charge shall be made in accordance with the accrual of time. (Paragraph incorporated by art. 14 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

In the case of issuance or acquisition of such values at prices below or above the residual nominal value, in the case of human persons and indivisous successions, the price differences will be charged in accordance with the procedures set out in subparagraphs (c) and (d) of the second article without an aggregate number following Article 90. (Paragraph incorporated by art. 14 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

(b) The other proceeds shall be charged to the fiscal year in which they were perceived, except for the first category to be charged by the method of the proceeding.

The profits referred to in the articles without number added in first, fourth and fifth order following article 90 shall be charged to the fiscal year in which they were perceived. In the case of non-numbered items added in fourth and fifth order following article 90, when operations are paid in dues due in more than one fiscal year, gains shall be charged in each year in the proportion of assessed contributions received in the latter. (Second paragraph incorporated by art. 15 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

The fees of directors, trustees or members of the monitoring councils and the retributions to the managing partners shall be charged by such subjects to the fiscal year in which the assembly or meeting of partners, as appropriate, approves their assignment.

The proceeds resulting from retirements or pensions liquidated by the retirement boxes and those resulting from the performance of public office or personal work carried out in relation to dependency that as a result of retroactive modifications of collective labour agreements or statutes or escalaphones, court judgement, filing or ruling of administrative appeal by competent authority, are perceived in a fiscal year and have been accrued in prior periods, may be charged to prosecutors by their beneficiaries. The exercise of this option will imply the waiver of the prescription earned by the taxpayer.

Where the imputation is appropriate according to its accrual, the accrual shall be effected in time, provided that the interest is stipulated or presumed, except those produced by the furniture values, rents and other similar characteristics.

The preceding provisions on the imputation of profit shall be applied correlatively to the imputation of expenses unless otherwise provided. Expenditures not attributable to a particular source of profit shall be deducted in the period in which they are paid.

The differences in tax from adjustments and their respective interests will be computed in the tax balance of the exercise in which the tax balances are required by the Fisco or in which they are paid, as the appropriate method used for the charge of the expenses. (Paragraph replaced by art. 1 p. 10 of the Act No. 27.346 B.O. 27/12/2016. Proceedings: from publication in the Official Gazette and effect for current fiscal exercises on the date of entry into force of the Reference Act.

Where appropriate to impute the profits according to their perception, they shall be considered perceived and the expenses shall be deemed to be paid, when they are charged or paid in cash or in kind, and, in addition, in cases where, when available, they have been credited to the account of the holder or, with the express or tacit authorization or conformity thereof, they have been reinvested, accumulated, capitalized, placed in reserve or in any form of any other form,

With regard to private retirement insurance schemes administered by entities subject to the control of the SUPERINTENDANCE OF FOLLOWERS, they will be recognized only when they are charged: (a) the benefits derived from the fulfillment of the requirements of the plan, and (b) the ransoms for the withdrawal of the insured from the plan for any cause.

In the case of erogations made by local companies that result from Argentine source gains for persons or entities of the foreigner with which such companies are linked or for persons or entities located, constituted, settled or domiciled in non-cooperative or lower jurisdictions or no taxation, the imputation to the tax balance may be made only when any of the cases specified in the sixth paragraph of this article are paid or configured, (Last paragraph replaced by article 16 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

COMPENSATION OF GOVERNMENTS

Art. 19 - In order to establish the set of net gains from Argentine sources of humans and indivisous successions residing in the country, the net results obtained in the fiscal year, within each and between the different categories, will be offset.

First, such compensation shall be made in respect of the net results obtained within each category, except for the profits from the investments .including the digital currencies. and operations referred to in Chapter II of Title IV of this Law. In addition, if it is to be caused by such investments and operations, this will be of a specific nature and must therefore be compensated exclusively with future gains from the same source and class. It is understood by class, to the set of profits covered in each of the articles of Chapter II.

If, by application of the compensation set out in the preceding paragraph, they would be broken into one or more categories, the amount would be offset by net gains from the second, first, third and fourth categories, etc.

For the purposes of this article, the amounts authorized by law to be deducted by the concepts specified in article 23.

In respect of the subjects covered by article 49, subparagraphs (a), (b), (c), (d), (e) and in its last paragraph, the breaches of:

(a) The disposal of shares, representative values and certificates of deposit of shares and other values, quotas and social participations .including shares of common investment funds and certificates of participation of financial trusts and any other right on trusts and similar contracts., digital currencies, Titles, bonds and other values, whatever the subject that obtains them.

(b) The implementation of the activities referred to in the second paragraph of article 69.

Also, and anyone who experiences them, the breaches generated by rights and emerging obligations of derivative instruments or contracts shall be considered as of a specific nature, except for coverage operations. For this purpose, a derivative transaction or contract shall be considered as a cover operation if it is intended to reduce the effect of future fluctuations in prices or market rates, on the assets, debts and results of the or major economic activities.

Exploited from activities related to the exploration and exploitation of living and non-living natural resources, developed on the continental shelf and in the exclusive economic zone of the Argentine Republic, including the artificial islands, installations and structures established in that area, can only be compensated with net gains from Argentine source.

Tax breaks shall not be compensable with profits that must tax the tax on a single and definitive basis or those covered by Chapter II of Title IV.

The tax break suffered in a fiscal period that cannot be absorbed with tax gains of the same period may be deducted from the encumbered gains obtained in the following immediate years. After five (5) years comcompputed according to the provisions of the Civil and Commercial Code of the Nation. after the one in which the loss occurred, no deduction may be made of the remaining breach, in successive periods.

Debriefs considered of a specific nature can only be computed against the net profits of the same source and that come from the same type of operations in the fiscal year in which the losses were experienced or in the next five (5) years .compputed according to the Civil and Commercial Code of the Nation—.

The breaches will be updated taking into account the variation in the index of internal prices to the wholesale (IPIM), published by the National Institute of Statistics and Censuses, operated between the month of the closing of the fiscal year in which they originated and the month of the closing of the fiscal year that is liquidated.

Debriefs from activities whose results are considered as a foreign source may only be compensated with profits from the same source and shall be governed by the provisions of article 134 of this Act.

(Article 17 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

EXENCTIONS

Art. 20 - They are exempt from the gravel:

(a) The profits of the national, provincial and municipal fiscos and those of the institutions belonging to them, excluding the entities and agencies covered by article 1 of Act No. 22.016.

(b) The profits of entities exempted from taxes by national laws, as long as the waiver they agree includes the levy of this law and provided that the profits derive directly from the exploitation or main activity that motivated the exemption to such entities.

(c) Remunerations received in the performance of their duties by diplomats, consular agents and other official representatives of foreign countries in the Republic; gains derived from buildings owned by foreign countries intended for office or house of their representative and interest from their tax deposits, all subject to reciprocity.

(d) The profits of cooperative societies of any nature and those that under any denomination (return, share interest, etc.), distribute the consumer cooperatives among their partners.

(e) The gains of religious institutions.

(Note: Decree No. 1.092/97 (B.O. 27/10/97) states that the Institutes of Consecrated Life and the Societies of Apostolic Life belonging to the Roman Catholic Church will benefit from the treatment provided by this paragraph without the need for any additional processing, sufficient the certification issued by the Ministry of Foreign Affairs, International Trade and Worship for this purpose. )

(f) The gains obtained by associations, foundations and civil entities of social assistance, public health, charity, education and instruction, scientific, literary, artistic, union and those of physical or intellectual culture, provided that such gains and social heritage are intended for the purposes of their creation, and in no case are distributed, directly or indirectly, among the partners. These exemptions exclude those entities that obtain their resources, in whole or in part, from the exploitation of public shows, gambling, horse racing and similar activities, as well as credit or financial activities .except the financial investments that could be made for the purpose of preserving social heritage, including those made by the Colleges and Professional Councils and the Social Insurance Funds, created or recognized by national legal standards.

The exemption referred to in the first paragraph shall not be applicable in the case of foundations and associations or civil entities of a group nature that develop industrial or commercial activities, except where industrial or commercial activities relate to the object of such entities and the income they generate does not exceed the percentage determined by the regulation of total incomes. In the event of overcoming the established percentage, the waiver shall not apply to the results of such activities. (Incision replaced by art. 18 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

(Note: Decree No. 1.092/97 (B.O. 27/10/97) states that the Institutes of Consecrated Life and the Societies of Apostolic Life belonging to the Roman Catholic Church will benefit from the treatment provided by this paragraph without the need for any additional processing, sufficient the certification issued by the Ministry of Foreign Affairs, International Trade and Worship for this purpose. )

(g) The gains of mutual entities that meet the requirements of the relevant legal and regulatory standards and the benefits they provide to their partners.

(h) Interests arising from savings deposits and special savings accounts, made in institutions subject to the legal regime of financial entities regulated by law 21.526 and their modifications. (Incision replaced by art. 19 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

(Note: The Decree No. 1.472/97Article 1 (B.O. 5/1/98) extends until 31 December 1998 the validity of the exemption set out in this paragraph. )

(decision). (Incision deleted by Act No. 25.402(a), B.O. 12/1/2001.- Proceedings: From 12/1/2001 onwards and will be effective for the interest received from 1 January 2001, inclusive.

(i) Interests recognized in judicial or administrative headquarters as accessories of labor credits.

Antiquity compensation in cases of dismissals and those received in the form of capital or income due to death or disability caused by accident or disease, whether payments are made pursuant to what determines civil and special social insurance laws or as a result of a insurance contract.

Retirements, pensions, retirements, subsidies, and continuing remuneration during sick leave or absences are not exempt, compensation for lack of notice in dismissal and benefits or rescues, net of non-deductible contributions, derived from private retirement insurance schemes administered by entities subject to the control of the SUPERINTENDENCIA DE SEGUROS, except those originated in the insured person ' s incapacity.

(j) Until the sum of TEN MIL PESOS ($ 10,000) per fiscal period, the profits from the exploitation of copyright and the remaining gains derived from rights protected by Law No. 11.723, provided that the tax relapses directly on the authors or their beneficiaries, that the respective works are duly registered in the NATIONAL DIRECTION OF THE RIGHT OF AUTOR, that the benefit of the publication, performance This exemption will not be applicable to foreign beneficiaries.

(k) (Subparagraph repealed by art. 80 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

(Note: Act No. 23,871, article 16 (B.O. 30/10/90) provided: The transfer of public titles originating in mandatory conversions of financial assets by the executive branch shall be exempt from any tax, reaching the first disposal of those who are holders for the above-mentioned cause and will have effect from 28/12/89, including. )

(l) The amounts received, by exporters in the category of Micro, Small and Medium-sized Enterprises under the terms of Article 1 of Law 25.300 and its supplementary rules, corresponding to refunds or refunds agreed by the Executive on taxes paid in the domestic market, which directly or indirectly affect certain products and/or their raw materials and/or services. (Included by art. 20 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

(m) The profits of sports associations and physical culture, provided that they do not persecute profits, exploit or authorize gambling and/or whose mere social activities deprive sports, in accordance with the regulations of the EXECUTIVE PODER.

The above-established exemption shall be extended to external associations, through reciprocity.

(n) The difference between the premiums or assessed contributions paid and the capital received at maturity, in the securities or bonds of capitalization and in the life and mixed insurances, except in the private retirement insurance schemes administered by entities subject to the control of the SUPERINTENDENCIA DE SEGUROS.

(o) The locative value and result derived from the alienation, of the house-habitation. (Incision replaced by art. 21 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

(p) The share emission premiums and the sums obtained by the limited liability companies, in simple comandite and in comandite for shares, in the part corresponding to the commadic capital, on the basis of the subscription and/or integration of quotas and/or social participations in amounts higher than the nominal value of them.

q) (Incision deleted by Act No. 25,239, Title I, art.1°, subparagraph (g). - Watch: From 31/12/99, the exercises starting from that date will take effect. )

(r) The profits of the international non-profit institutions, with legal status, with headquarters established in the Argentine Republic.

The profits of the non-profit institutions referred to in the preceding paragraph, which have been declared of national interest, are also considered to be included in this paragraph, even if they do not credit legal status granted in the country or headquarters in the Argentine Republic.

(s) The interests of promotional loans granted by international agencies or foreign official institutions, with the limitations to be determined by regulation.

(t) Interests generated by credits obtained abroad by national, provincial, municipal or Autonomous City of Buenos Aires and the Central Bank of the Argentine Republic. (Incision replaced by Act No. 25.063, Title, art.4°, subparagraph (h). - Proceeding: From its publication in the Official Gazette and effect will be given to the periods that close after the entry into force of this law or, if any, the current fiscal year to that date. )

(u) Donations, inheritances, legacies and benefits achieved by the Law on Taxes of Certain Games and Sports Contests. (Incision replaced by Act No. 25,239, Title I, art.1°, subparagraph (h). - Watch: From 31/12/99, the exercises starting from that date will take effect. )

(v) The amounts from credit updates of any origin or nature. In the case of updates for credits set up for gains to be charged by the perceived system, the waiver will only proceed for updates after the date on which the imputation corresponds. For the preceding purposes, the differences in change shall be deemed to be included in this subparagraph.

The updates referred to in this subparagraph - excluding exchange differences and updates set by law or judicially - must come from an express agreement between the parties.

The provisions of this subparagraph shall not be applicable for payments made in the case provided for in the fourth paragraph of Article 14, nor shall they meet updates whose exemption from this tax had been made by special laws or which constitute foreign source gains.

(Note: The Decree No. 1.472/97Article 1 (B.O. 5/1/98) extends until 31 December 1998 the validity of the exemption set out in this paragraph. )

(w) The results from operations of sale, change, permute or disposition of actions, representative values of actions and certificates of deposit of actions, obtained by human residents and indivisous successions based in the country, provided that such operations are not attributable to subjects covered by subparagraphs (d) and (e) and the last paragraph of article 49 of the law. The waiver shall also apply to those subjects to the repurchase of shares of common investment funds of the first paragraph of article 1 of Act 24,083 and their modifications, while the fund is included, at a minimum, in a percentage determined by the regulation, provided that they meet the conditions mentioned in the following paragraph.

The benefit provided in the preceding paragraph shall be applied only to the extent that (a) a public tender placement with the authorization of the National Securities Commission; and/or (b) operations have been carried out in markets authorized by that agency under segments that ensure the priority time price and interference of offers; and/or (c) are made through a public procurement and/or exchange offer authorized by the National Securities Commission.

The exemption referred to in the first paragraph of this subparagraph shall also apply to investment, trustees and other entities that possess the character of tax subjects or tax obligations, constituted as a product of privatization processes, in accordance with the provisions of Chapter II of Law 23,696 and concordant rules, as long as they are operations with actions originated in participatory ownership programmes, implemented under Chapter III.

The exemption provided for in this subparagraph will also be applicable to foreign beneficiaries to the extent that such beneficiaries do not reside in non-cooperative jurisdictions or funds invested do not come from non-cooperative jurisdictions. In addition, the interests or returns and the results of the sale, exchange, permute or disposition of the following values obtained by the beneficiaries of the foreign country mentioned above: (i) public titles .titles, bonds, letters and other obligations issued by the national, provincial, municipal and the Autonomous City of Buenos Aires.

The provisions of the preceding paragraph shall not apply in the case of letters from the Central Bank of the Argentine Republic (LEBAC).

The National Securities Commission is empowered to regulate and monitor, within its competence, the conditions laid down in this article, in accordance with the provisions of Act No. 26.831. (Section w) replaced by art. 22 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

(y) The gains derived from the disposal of waste, and in general all types of activities related to the sanitation and preservation of the environment, including advice, obtained by the entities and agencies covered by article 1 of Law 22.016 on condition of their reinvestment in those purposes. (Input input Act No. 25.063, Title, art.4°, subparagraph (i). - Proceeding: From its publication in the Official Gazette and effect will be given to the periods that close after the entry into force of this law or, if any, the current fiscal year to that date. Note: Decision observed by the Executive Power by Decree No. 1.517/98. Insistence of sanction by Chambers of Deputies and Senators, PE ­ 242/99 (B.O. 2/8/99).

(z) The difference between the value of the extra hours and that of the ordinary hours, which the workers perceive in relation to dependency for the services provided on holidays, inability and during the weekends, calculated according to the corresponding labour legislation. (Included by art. 1 p. 1 Act No. 27.346 B.O. 27/12/2016. Vigencia: from its publication in the Official Gazette and will take effect from the fiscal year 2017, inclusive.

When active interests under subparagraph (h) or active updates referred to in subparagraph (v) coexist with the interests or updates referred to in article 81 (a), the waiver shall be limited to the positive balance arising from the compensation thereof. (Párrafo replaced by Act No. 25,239, Title I, art.1°, subparagraph (i). - Watch: From 31/12/99, the exercises starting from that date will take effect.

The exemption provided for in subparagraphs (f), (g) and (m) shall not be applicable to those institutions included in the same ones that during the fiscal period assign to any of the persons who are part of the executive, counter-release of the same ones (directors, counselors, trustees, reviewers of accounts, etc.), whatever their denomination, an amount for any average amount, including the cost of the highest annual compensation Nor will the aforementioned exemptions be applied, whatever the amount of the retribution, for those entities that have enclosed the payment of them by the rules governing their constitution and functioning.

(Last paragraph of article 20 deleted by Act No. 25.063Chapter III, article 4 (j). - Watch: From 1/1/99.)

(Note: Monitoring of exemptions set out in subparagraphs (h), (q) and (v) (paragraphs (h), (t) and (z) of the text ordained in 1986) extended until 31/12/87, 31/12/88, 31/12/89, 31/12/90, 31/12/91, 31/12/92, 31/12/93, 31/12/94, 31/12/95, 31/12/96, 31/12/97 and 31/12/97 2.380/86, 2.073/87, 1.936/88, 1.620/89, 2.649/90, 2.743/91, 2.416/92, 182/94, 2.207/94, 11/96, 1.477/96 and 1.472/97respectively.)

Art. 20 bis.- In addition to the provisions of article 20, they are exempt from tax:

- Remuneration from compulsory guards, whether active or passive, by professionals, technicians, assistants and operating personnel of public health systems, when the provision of the service is carried out in a public health centre located in unfavourable health areas as declared by the national health authorities, to proposals from the provincial health authorities.

(Article 6 of the Act No. 27.480 B.O. 21/12/2018. Watch: from the day after your publication in the Official Gazette and will result in application for fiscal years 2019 and following)

Art. 21 -Total or partial exemptions or deductions affecting the taxation of this law, including or not therein, shall not result in any effect to the extent that it may result in a transfer of income to foreign fiscos. The above provisions shall not be applicable in respect of the exemptions set out in subparagraphs (t) and (w) of the preceding article and of the first and fourth articles incorporated without number following article 90 or when it affects international agreements signed by the Nation in respect of double taxation. The transfer measure shall be determined in accordance with the records to be provided by taxpayers. In the event that such a contribution is not made, the total transfer of exemptions or removals shall be presumed, and the treatment provided by this law shall be granted to the respective amounts in accordance with the type of proceeds in question. (Paragraph replaced by art. 23 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

For this purpose, the certificates issued in the foreign country by the relevant implementing agencies or by the professionals authorized to do so in that country shall be considered sufficient evidence. Relevant legalization by Argentine consular authority shall be indispensable in all cases.

SEPELIO COSTS

Art. 22 - Of the profit of the fiscal year, whatever its source, with the limitations contained in this law and provided that the requirements established by the regulation are met, the costs of sepelial incurred in the country may be deducted, to the sum of CUATRO CENTAVOS DE PESO ($ 0.04) originated by the death of the taxpayer and for each of the persons to be considered to be 23.

Non-IMPONIBLE AND FAMILY CHARGE

Art. 23 ! Human persons shall be entitled to deduct from their net gains: (Expression is a visible existence, replaced by shihumans. by art. 79 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

(a) In respect of non-imposable gains, the sum of fifty-one thousand nine hundred sixty-seven pesos ($ 51,967), provided that the persons indicated are residents of the country.

(b) In the case of family burdens, provided that the persons indicated are resident in the country, are in charge of the taxpayer and do not have in the year net income exceeding fifty and one thousand nine hundred sixty-seven ($ 51,967), regardless of origin and whether or not they are subject to the tax:

1. Weights forty-eight thousand four hundred forty-seven ($ 48,447) for the spouse.

2. Weights twenty-four thousand four hundred thirty-two ($ 24.432) for each son, daughter, stepdaughter or stepdaughter under eighteen (18) years or disabled for work.

The deduction of this subparagraph may only be made by the closest relative with taxable gains.

(c) For special deduction, up to an amount equivalent to the amount resulting from the increase in the amount referred to in subparagraph (a) of this article:

1. Once (1), in the case of net gains under Article 49, provided that they work personally in the activity or enterprise and net profits included in Article 79, except that they are included in the following paragraph. In such cases, the increase will be from a five comma (1,5) times, instead of one (1) time, when it comes to a self-employed or self-employed entrepreneurs, in the terms established by the regulation.

It is an indispensable condition for the computation of the deduction referred to in this section, in relation to the respective incomes and activity, the payment of the contributions that, as self-employed, must be made compulsory to the Argentine Integrated Previsional System (SIPA) or the appropriate substitute retirements.

2. Three comma eight (3.8) times, in the case of net gains covered by article 79 (a), (b) and (c). (Paragraph replaced by art. 24 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

The regulation shall establish the procedure to be followed when profits are obtained under both sections. (Paragraph replaced by art. 24 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

The deduction provided for in the second subparagraph of the first paragraph of this subparagraph shall not be applicable in the case of remuneration covered by article 79 (c), originated in special forecast schemes which, depending on the position of the beneficiary, provide a differential treatment of the provision, mobility of benefits, as well as the age and number of years of service to obtain the retirement benefit. Exclude from this definition to the differential regimes set up under painful or unhealthy activities, determinants of premature old age or depletion and the regimes corresponding to the educational, scientific and technological activities and withdrawal of the armed and security forces. (Paragraph replaced by art. 24 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

The Federal Public Income Administration, an auto-archic entity within the Ministry of Finance and Public Finance, shall determine the manner in which the deductions provided for in this article are calculated in respect of the income set out in article 79 (a), (b) and (c) for the purpose of the retention agents dividing the annual grant

Complementary for twelve (12) and add the twelfth part of this emolument to the remuneration of each month of the year.

In the case of employees in relation to dependency who work and retirees who live in the provinces and, where appropriate, party, who mentions article 1 of Law 23.272 and its modifications, computable personal deductions will be increased by twenty-two percent (22%).

In respect of the incomes mentioned in article 79 (c) of the present, the deductions provided for in subparagraphs (a) and (c) of this article shall be replaced by a specific deduction equivalent to six (6) times the sum of the guaranteed minimum assets, as defined in article 125 of Law 24,241 and its amendments and supplements, provided that the latter amount exceeds the sum of the above deductions.

The provisions of the preceding paragraph shall not apply to those who perceive and/or obtain income of different nature from those provided for. Nor shall such deduction be appropriate for those who are obliged to tax the tax on personal property, provided that this obligation does not arise exclusively from the possession of a single housing property.

The amounts provided for in this article will be adjusted annually, starting from the fiscal year 2018, even by the coefficient that arises from the annual variation of the Average Immuneration of Stable Workers (RIPTE), corresponding to the month of October of the year prior to the adjustment for the same month of the previous year.

(Article replaced by art. 1 p. 2 Act No. 27.346 B.O. 27/12/2016. Vigencia: from its publication in the Official Gazette and will take effect from the fiscal year 2017, inclusive.

(Note Infoleg: by art. 1 Decree No. 1253/2016 B.O. 14/12/2016 it is stated that for the purpose of determining the tax on profits corresponding to the second quota of the Supplementary Annual Allowance of the year 2016, the amount of the special deduction calculated pursuant to the third paragraph of Article 23(c) of the Law of Tax on Gains, which was ordered in 1997 and its amendments, should be included in PESOS MIL ($ 15,000). It will have effects only for those individuals who obtain income mentioned in Article 79 (a), (b) and (c) of the said norm, when the highest monthly remuneration and/or gross earned, earned between the months of July and December of 2016, does not exceed the sum of CINCUENTA PESOS and CINCO MIL ($ 55,000). Watch: from the day of publication in the Official Gazette).

Art. ...: (Article Derogated by Article 1 of the Act No. 26.477 B.O. 24/12/2008. Watch: from the day of publication in the Official Gazette. Implementation from 1 January 2009)

Art. 24 - The deductions provided for in article 23, subparagraph (b), shall be effected for monthly periods, computing the entire month in which the cases determined by the computation of the computation (birth, marriage, death, etc.).

In the event of death, the deductions provided for in article 23 shall be effected on a monthly basis, all the month in which such an event occurs. For its part, the undivided succession, applying the same criterion, will compute the deductions to which the offender had been entitled.

The monthly amounts to be computed shall be those determined by the procedure referred to in the third paragraph of Article 25.

Art. 25 - The amounts referred to in articles 22 and 81, subparagraph (b), and the sections of the scale provided for in article 90, shall be updated annually by the application of the coefficient established by the IMPOSITTIVE GENERAL DIRECTION on the basis of the data to be provided by the NATIONAL INSTITUTE OF STATISTIC AND CENSES.

The updated coefficient to be applied will be calculated taking into account the variation in price indices at the wholesale level, relating the average monthly indices for the respective fiscal year to the average monthly indices for the previous immediate fiscal year.

The amounts referred to in Article 23 shall be fixed annually considering the sum of the respective updated monthly amounts. These monthly amounts will be updated each month the amount corresponding to the previous month, beginning in January on the basis of the month of December of the previous fiscal year, according to the variation in the price index to the greater, general level, elaborated by the NATIONAL INSTITUTE OF STATISTICA AND CENSOS.

When the IMPOSTITIVE GENERAL DIRECTION establishes retentions of the levy on the earnings covered by article 79 (a), (b), (c) and (e), it shall, on a provisional basis, effect updates of the monthly amounts in accordance with the procedure provided for in each case. However, retention agents may choose to make adjustments on a quarterly basis.

La GENERAL DIRECTION IMPOSITIVA will be able to round up in multiple DOCE (12) the amounts updated pursuant to this article.

RESIDENCE CONCEPT

Art. 26 - For the purposes of the deductions provided for in article 23, humans living more than SEIS (6) months in the country during the fiscal year are considered resident in the Republic. (Expression is a visible existence, replaced by shihumans. by art. 79 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

For all purposes of this law, human persons who are abroad at the service of the Nation, provinces, Autonomous City of Buenos Aires or municipalities and officials of Argentine nationality who act in international bodies of which the Argentine Republic is a member State are also considered resident in the country. (Paragraph replaced by art. 25 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

CONVERSION

Art. 27 - All goods entered in the country or given or received in payment, without a certain price in Argentine currency, must be valued in pesos at the date of receipt in payment, except special provision of this law.

To that end, the provisions of article 68 shall apply, where appropriate.

GANANCIA OF COMPONENTS OF SOCIEDAD CONYUGAL

Art. 28 - (Article repealed by art. 80 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Art. 29 - It is appropriate to attribute to each spouse, whatever the property regime to which the marital society is subjected, the profits from:

(a) Personal activities (profession, trade, trade or industry).

(b) Own property.

(c) Other property, by the party or proportion in which it has contributed to its acquisition, or by 50 per cent (50%) where there is no possibility of determining it.

(Article 26 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Art. 30 - (Article repealed by art. 80 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

EDAD MENORES

Art. 31 - (Article repealed by art. 80 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

SOCIEDADES ENTRE WITHYUGES

Art. 32 - (Article repealed by art. 80 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

INDIVIDUAL SUBMISSIONS

Art. 33 - Indivisible successions are contributors to the gains that they obtain until the date of the declaration of heirs or the testament that meets the same purpose has been declared valid, subject to payment of the tax, subject to the calculation of the deductions to which the offender has been entitled, in accordance with article 23 and with the limitations imposed by it.

Art. 34 - The declaration of heirs or declared valid the testament and for the corresponding period until the date of the approval of the partition, judicial or extrajudicial account, the surviving spouse and the heirs shall add to their own profits the proportional part which, in accordance with their social or heirs law, corresponds to them in the gains of the succession. Legaries will add to their own profits those produced by legacy goods.

From the date of approval of the partition account, each of the beneficiaries shall include in their respective declarations the proceeds of the assets awarded to it.

Art. 35 - The final breach suffered by the offender may be compensated by the gains obtained by the succession to the date of the declaration of heirs or until the testament has been declared valid, as provided for in article 19.

If a balance still remains, the surviving spouse and heirs shall proceed in the same manner from the first exercise in which they include in the individual declaration gains produced by inheritance or inherited property. The compensation of the breaches referred to above may be made with encumbered gains obtained by the succession and by the heirs until the fifth year, even after that in which the breach originated.

Analogue temperament will adopt the surviving spouse and heirs with respect to the definitive breaches suffered by succession.

The portion of the definitive breach of the causator and the succession that each of the heirs and the surviving spouse may compensate in their affidavits will arise from prorating the broken ones in proportion to the percentage that each of the beneficiaries has in the heirty.

Art. 36 - When a taxpayer had followed the system of receipt, for the purpose of the liquidation of the tax, the proceeds produced or accrued but not collected until the date of their death shall be considered, if any, in any of the following forms:

(a) Including them in the last affidavit of the offender.

(b) Including them in the affidavit of succession, surviving spouse, heirs and/or legaries, in the year they perceive them.

NOT DOCUMENTED

Art. 37 - When an erogation lacks documentation, or it fits as an apocryphal, and is not proved by other means that by its nature it must be made to obtain, maintain and retain taxed profits, its deduction in the tax balance will not be admitted and will also be subject to the payment of the rate of thirty-five percent (35%) that will be considered definitive in replacement of the tax corresponding to the unknown or hidden beneficiary. For the purpose of determining this tax, the taxable act shall be deemed to be perfected on the date on which the erogation is made.

(Article replaced by Article 27 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Art. 38 - The income indicated in the previous article shall not be required in the following cases:

(a) When the IMPOSTITIVE GENERAL DIRECTION presupposes that the payments have been made to purchase goods.

(b) When the IMPOSTITIVE GENERAL DIRECTION presupposes that the payments - for their amount, etc. - do not become taxable in the hands of the beneficiary.

RETENTION

Art. 39 - The perception of the tax shall be carried out by retention in the source, in cases and in the manner provided by the IMPOSITTIVE GENERAL DIRECTION.

Art. 40 - Where the taxpayer has not complied with its obligation to retain the tax in accordance with the existing rules, the taxpayer's tax balance may, for the purposes of the tax balance, challenge the taxpayer's expense.

PART II CATEGORY OF CHAPTER I GANANCIES OF THE FIRST CATEGORY

RENTA DEL SUELO

Art. 41 - As long as it is not appropriate to include them in article 49 of this law, they constitute gains of the first category, and must be declared by the owner of the respective real estate:

(a) The one produced in money or in kind of the location of urban and rural properties.

(b) Any kind of counterfeit that is received by the constitution for third parties of usufruct rights, use, room, anticresis, surface or other real rights. (Incision replaced by art. 28 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

(c) The value of the improvements made in the properties, by tenants or tenants, which constitute a benefit to the owner and to the party that the owner is not obliged to compensate.

(d) The direct or territorial contribution and other levies taken by the tenant or tenant.

(e) The amount paid by tenants or tenants for the use of furniture and other accessories or services provided by the owner.

(f) The computable locative value for the properties that their owners occupy for recreation, summer or other similar purposes.

(g) Locative value or presumed lease of property that has been granted free of charge or at an undetermined price.

The profits that the owners obtain for the production, in money or in kind, of urban or rural properties given in sublocation are also considered to be of first category.

Art. 42 - It is presumed, except proof to the contrary, that the locative value of any property is not less than the locative market value that governs in the area where the property is located, according to the guidelines set by the regulation.

Where real rights of usufruct, use, room, anticresis, surface or others are transferred or constituted on these grounds, for a price lower than that of the market that governs in the area where the property is located, the Federal Public Income Administration may, of course, estimate the corresponding profit.

(Article 29 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Art. 43 - Those who perceive leases in kind will declare as profit the value of the products received, understood by such that of their realization in the fiscal year or, in default, the price of square at the end of the same. In the latter case, the difference between the sale price and the quoted square price will be computed as a profit or break from the year the sale was made.

Art. 44 - The taxpayers who freely transmit the invalid property of the property, retaining for themselves the right to the fruits - of any kind that they may be - use or room, must declare the profit that produces them the exploitation or the locative value, as appropriate, without deducting any amount for rents or leases, even if their payment has been stipulated.

CHAPTER II GANANCIES OF THE SECOND CATEGORY

OF CHAPTERS

Art. 45 - As long as it is not appropriate to include them in article 49 of this Act, they constitute gains in the second category:

(a) The rent of titles, cédulas, bonds, letters of treasury, musttures, captions or credits in privileged money or values, or chirografarios, contain or not in public writing, and any sum that is the product of the placement of the capital, whatever its denomination or form of payment.

(b) The benefits of locating movable things and rights, royalties and periodic subsidies.

(c) Vital income and profits or life insurance shares.

(d) The net benefits of non-deductible contributions resulting from compliance with the requirements of private retirement insurance schemes administered by entities subject to the control of FOLLOW-UP SUPERINTENDANCE, as soon as they do not have their origin in personal work.

(e) Net repurchase of non-deductible contributions, due to the withdrawal insurance schemes referred to in the preceding paragraph, except as provided for in article 101.

(f) The amounts received in payment of obligations not to do or for the abandonment or non-exercise of an activity. However, these gains will be considered as the third or fourth category, as appropriate, when the obligation is not to engage in trade, industry, profession, trade or employment.

(g) The share interest that cooperatives distribute, except for consumption. In the case of cooperatives called labour, the provisions of article 79, subparagraph (e), shall apply.

(h) Income that in the form of one or more payments are perceived by the definitive transfer of key rights, brands, invention patents, royalties and similar, even if this type of operation is not usually performed.

(i) The dividends and profits, in money or in kind, that distribute to their shareholders or partners the companies covered in Article 69 (a).

(j) Results originated by emerging rights and obligations of derivative instruments and/or contracts.

Also, when a set of transactions with derivative instruments and/or contracts is equivalent to another transaction or financial operation with a treatment established in this law, the rules of transactions or operations of which it is equivalent shall apply to such a set. (Input input Act No. 25.063, Title III, art.4°, subparagraph (l). - Proceeding: From its publication in the Official Gazette and effect will be given to the periods that close after the entry into force of this law or, if any, the current fiscal year to that date. )

(k) Results from stock disposal operations, representative values and certificates of deposit of shares and other values, quotas and social participations .including shares of common funds of investment and certificates of participation of trusts and any other right on trusts and similar contracts digitales, digital currencies, Titles, bonds and other values, as well as for the disposal of property or transfers of rights on property. (Incision replaced by art. 30 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Art. 46 - The dividends, in money or in kind, shall be regarded as profits taxed by their beneficiaries, whatever the business funds with which their payment is made, including the previous reserves regardless of the date of their constitution and the profits exempted in accordance with the provisions of this law and from emission premiums. The same treatment will have the benefits that the subjects covered in Article 69, paragraphs 2, 3, 6, 7 and 8 (a), distribute to their partners or members.

The dividends in kind will be computed to their current value in square at the date of their making available.

Distributions in actions released from revaluation or accounting adjustments and the capitalization of liquid and realized profits shall not be computed by the beneficiaries for the purpose of determining their tax gain or for the calculation referred to in article 80 of the law.

In the case of total or partial rescue of shares, the distribution dividend will be considered to differentiate between the ransom amount and the computable cost of the shares. In the case of actions released, it will be considered that their computable cost is equal to zero (0) and that the total amount of the ransom constitutes a taxed dividend.

The computable cost of each, action will be obtained considering as numerator the amount attributed to the net asset in the trade balance of the last period closed by the issuing entity, immediately prior to the rescue, deduced the liquid and realized profits that integrate it and the reserves that originate in utilities that meet the same condition, and as denominator the actions in circulation.

When the stocks that are rescued have been purchased from other shareholders, it will be understood that the ransom involves an alienation of those shares. In order to determine the outcome of such an operation, the corresponding computable cost in accordance with the provisions of the preceding paragraph shall be considered as a selling price and as a cost of acquisition that is obtained from the application of article 61 of the Act.

(Article 31 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Art. ... - It shall be presumed that the making available to dividends or assimilable profits, in the terms of article 18 of this law, as provided for in paragraph 5 of subparagraph (a), has been set up, when any of the situations listed below are verified, in the magnitude foreseen for each of them:

(a) Owners, owners, partners, shareholders, shareholders, fiduciantes or beneficiaries of the subjects covered by Article 69 make withdrawals of funds for any cause, in the amount of such withdrawals.

(b) Owners, owners, partners, shareholders, shareholders, fiduciantes or beneficiaries of the subjects covered by Article 69 have the use or enjoyment, by any Title, of assets of the entity's asset, fund or trust. In this case, it will be presumed, admitting proof to the contrary, that the value of the dividends or profits made available is eight percent (8%) yearly of the current value in place of the real estate and twenty percent (20%) yearly of the current value in place for the rest of the property. If payments are made in the same fiscal period for the use or enjoyment of such goods, the amounts paid may be discounted for the purpose of calculating the dividend or profit.

(c) Any asset of the entity, fund or trustee is affected by the guarantee of direct or indirect obligations of the holders, owners, partners, shareholders, shareholders, trustees or beneficiaries of the subjects covered by Article 69 and the guarantee is enforced. If this is verified, the dividend or profit will be calculated with respect to the current value in place of the goods executed, up to the limit of the guaranteed amount.

(d) Any property that the subjects covered by Article 69 sell or buy their owners, owners, partners, shareholders, shareholders, fiduciants or beneficiaries of the subjects, below or above, as appropriate, the value of the square. In such case, the dividend or utility will be calculated by the difference between the declared value and the value of the square.

(e) Any expenditure incurred by the subjects covered by article 69, in favour of their owners, owners, partners, shareholders, shareholders, trustees or beneficiaries, which do not respond to operations carried out in the interest of the company, in the amount of such erogations, except that the amounts were refunded, in which case Article 73 of the Act shall apply.

(f) The holders, owners, partners, shareholders, shareholders, fiduciants or beneficiaries of the subjects covered by Article 69 receive salaries, fees or other remuneration, while the actual service provision cannot be proved or the agreed retribution is appropriate to the nature of the services rendered or not higher than that paid to third parties for similar services.

In all cases, in relation to the amounts determined by the application of the situations provided for in the first paragraph of this article, the presumption set out in it shall limit the amount of the accrued profits at the end of the last period prior to the date on which any of the situations provided for in the preceding paragraphs is verified by the proportion of each holder, owner, partner, shareholder, shareholder, party or beneficiary. The presumption contained in the provisions of article 73 shall apply to the excess amounts.

It will also be considered that dividends or assimilable profits are made available when the assumptions regarding the spouse or convivor of the owners, owners, partners, shareholders, shareholders, fiduciants or beneficiaries of the subjects covered by Article 69 or their ascendants or descendants in the first or second degree of consanguinity or affinity are verified.

The same forecasts shall apply when societies and trustees under article 49 (b) and (c) elect to pay as capital societies in accordance with the provisions of the fourth paragraph of article 50, as well as the permanent establishments referred to in the second paragraph of article 69 (b).

(Article s/n incorporated after Article 46, by Article 32 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Art. 47 - For the purposes of this law, any counterfeit that is received, in money or in kind, by the transfer of domain, use or enjoyment of things or by the assignment of rights, the amount of which is determined in relation to a unit of production, sale, exploitation, etc., whatever the denomination assigned.

Art. 48 - Where the type of interest is not expressly determined, for the purposes of the tax, it is presumed, except evidence to the contrary, that any debt, whether it is the consequence of a loan, of sale of properties, etc., to a type of interest not less than that set by the BANCO of the ARGENTINA NATION for commercial discounts, except that corresponding to debts with legal update, agreed or established judicially, in which case they will be of application.

If the debt comes from property sales in the term, the presumption set out in the previous paragraph governs without admitting evidence to the contrary, even if it is expressly stipulated that the sale is made without computing interest.

Art. ... - (Article s/n incorporated after article 48, repealed by art. 80 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

CHAPTER III

THIRD CATEGORY GANANCIES

EMPRESARY BENEFITS

(Denomination of the Chapter replaced by art. 33 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Art. 49 - Income covered. Third category earnings:

(a) Those obtained by those responsible under article 69.

(b) All those that derive from any other kind of corporation incorporated in the country.

(c) The derivatives of trusts constituted in the country in which the fiduciant possesses the quality of beneficiary, except in the cases of financial trusts or when the fiduciant-beneficiary is a subject covered in Title V.

(d) The derivatives of other single companies located in the country.

(e) Those derived from the activity of Commissioner, Rematator, Recipient and other Trade Assistants, not expressly included in the fourth category.

(f) Those derived from lotteries for the purpose of urbanization, those derived from the construction and disposal of properties under the regime of horizontal ownership of the Civil and Commercial Code of the Nation and the development and disposal of properties under the regime of real estate sets provided for in the aforementioned code.

(g) Other gains not covered in other categories.

Compensations in cash and in kind, viats, etc., which are perceived by the exercise of the activities included in this article shall also be considered as gains in this category, as soon as they exceed the amounts that the Federal Public Income Administration finds reasonable in respect of reimbursement of expenses incurred.

When the professional or trade activity referred to in article 79 is complemented by commercial exploitation or vice versa (sanitary, etc.), the total result obtained from all of these activities shall be regarded as a third category gain.

(Article replaced by art. 34 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Art. 50 - The result of the tax balance of single-person enterprises covered by Article 49(d) and of the companies included in Article 49(b) shall be deemed, if any, entirely assigned to the owner or distributed among the partners even if it has not been credited to their private accounts.

The results obtained by trustees under article 49 (c) will also be attributed to the trustees at the end of the fiscal year, as appropriate.

The provisions contained in the preceding paragraphs shall not be applicable in respect of the breaches which, in accordance with the provisions of article 19, are considered of a specific nature for the subjects

The provisions contained in the preceding paragraphs shall not be applicable in respect of the breaches which, in accordance with the provisions of article 19, are considered of a specific nature for the subjects covered by article 49 (b), (c) and (d), which shall be compensated by the company, society or trustee in the manner provided for by the first of the above-mentioned articles, depending on the origin of the breach.

Nor shall the provisions contained in the first two paragraphs of this article apply, whereas the above-mentioned societies and trusts covered by article 49 (b) and (c) have exercised the option referred to in article 69 (a) (a)).

(Article replaced by art. 35 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Art. 51 - Where profits come from the disposal of exchange goods, the total net sales will be grossly accounted for less the cost to be determined by application of the following items.

Net sales will be considered the value of deducting from gross sales the returns, bonuses, discounts or other similar concepts, according to the customs of the square.

Art. 52 - In order to carry out the tax balance, the existence of exchange assets - other than property - must be computed using the following methods for its determination:

(a) Resale goods, raw materials and materials: At the cost of the last purchase made in the DOS (2) months prior to the closing date of the exercise. If purchases had not been made in that period, the last purchase will be taken in the period, updated from the date of purchase to the date of end of the year.

Where there are no purchases during the period, the tax value of the goods will be taken in the initial inventory, updated from the start date to the end of the year.

(b) Outputs produced:

1. The value to be considered will be calculated based on the price of the last sale made in the DOS (2) months prior to the end of the year, reduced in the amount of the sales expenses and the net profit margin contained in that price.

If there are no sales in the precited period, the calculation will consider the price of the last sale made less the sales expenses and the net profit margin contained in the price, updating the resulting amount between the date of sale and the closing of the year.

Where no sales have been made, the sale price for the taxpayer shall be considered at the end of the period less the sales expenses and the net profit margin contained in that price.

2. When systems are carried that allow the determination of the cost of production of each item of processed products, the same method will be used as the one established for the valuation of stocks of resale goods, considering as the date of purchase the time of completion of the development of the goods.

In these cases, the allocation of raw materials and materials to process shall be carried out taking into account the method set for the valuation of the stocks of such goods.

(c) Outputs under preparation: The value of the finished products, established in accordance with the previous paragraph, shall be applied to the end of the year.

(d) Hacienda:

1. Stocks of breeding establishments: the estimated cost per annual revaluation.

2. The stocks of winter establishments: at the price of place for the taxpayer to the date of closing of the exercise in the market where it is used to operate, less the sales expenses, determined for each category of hacienda.

(e) Cereals, oleaginous, fruits and other products of the land, except forest farms:

1. With well-known quote: at the price of square less sales expenses, at the closing date of the year.

2. No known quote: at the sale price fixed by the taxpayer less sales expenses, at the closing date of the year.

(f) Sementeras: To the amount that results from updating each of the investments from the date they were made to the date of end of the year or to the likely value of realization to this last date when the requirements provided for in Article 56 are met.

Inventories should state in detail the existence of each item with its respective unit price.

Inventory valuations will not allow deductions globally, by general reserves established to deal with price fluctuations or other contingencies.

For the purpose of updating provided for in this article, the rates to be applied shall be those referred to in article 89.

For the purposes of this law, shares, representative values and certificates of deposit of shares and other values, quotas and social participations .including shares of common funds of investment and certificates of participation in financial trusts and any other right on trusts and similar contracts., digital currencies, Titles, bonds and other values, shall not be considered as assets of change and, consequently, shall be governed by the specific rules governing such property. (Last paragraph replaced by art. 36 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Art. 53 - For the purpose of the implementation of the annual revaluation estimate cost system, the following will be done:

(a) Hacienda bovina, ovina and porcina, with the exception of those indicated in subparagraph (c): the value of each species will be taken as the base value of the category most sold during the last three (3) months of the exercise, which will be equal to the SESENTA BY CIENTO (60 %) of the weighted average price obtained by the sales of that category in the aforementioned period.

If the term had not been sold by animals of their own production or were not representative, the value to be taken as a basis would be that of the category of farms acquired in greater quantity during the course, which will be given by SESENTA BY CIENTO (60 %) of the weighted average price paid by the purchases of these categories in the period mentioned.

If the forecasts of the preceding paragraphs are not applicable, the SESENTA FOR SCIENTO (60 %) of the weighted average price that in the aforementioned period had been recorded for the most sold category of hacienda in the market in which the rancher used to operate.

In all cases the value of the remaining categories shall be established by applying to the determined base value, the ratio indexes contained in the tables annexed to Act No. 23.079.

(b) Other farms, with the exception of those considered in subparagraph (c): the value to practice the avalúo - by head and without distinction of categories - will be equal in each species to the SESENTA BY CIENTO (60 %) of the weighted average price that in the THRE (3) last months of the exercise arises from its sales or purchases or, in the absence of both, of the operations recorded for the species in the market where the cattle rancher usually operates.

(c) Vientres, understood by such those who are destined to fulfill this purpose: it will be taken as an avaluum value to apply to the value that at the beginning of the exercise had the category to which the belly belongs to its completion, the same coefficient used for the calculation of the tax inflation adjustment.

(d) The system of avalúo applied to the belly may be used by breeding cattle ranchers for the entire estate of its own production, when the entire production cycle is carried out in establishments located outside the central livestock area defined by resolutions J-478/62 and J-315/68 of the ex-JUNTA NACIONAL DE CARNES.

The final stocks of the activity initiation exercise will be assessed according to the procedure established by the regulation according to the purchases of the activity.

Art. 54 - For the purposes of this tax, the entire estate, whatever its category, is considered as merchandise of an agricultural establishment.

However, for the purposes of article 84, the treatment of fixed assets will be granted to acquisitions of players, including females, where they are pedigree or pure by cross.

Art. 55 - In order to carry out the tax balance, the stocks of real estate and construction works that are of the nature of exchange assets shall be computed for the amounts determined in accordance with the following rules:

(a) Real estate:

To the acquisition value -including the costs necessary to carry out the operation - updated from the date of purchase to the date of end of the year.

(b) Real estates built:

The value of the ground, determined in accordance with the previous subparagraph, will be added the updated construction cost from the date of completion of the construction to the date of end of the year. The cost of construction will be established to update the amounts invested in the construction, from the date each investment had been made to the date of completion of the construction.

(c) Construction:

The value of the land, determined in accordance with subparagraph (a), shall be added to the amount resulting from updating the amounts invested from the date the investment was made to the date of the end of the year.

(d) Improvements:

The value of the improvements will be determined by updating each of the inverted amounts, from the date the investment was made to the date of completion of the improvements and the amount obtained will be updated from the latter date to the end of the year. In the case of ongoing improvements, investments will be updated from the date on which they were made until the end of the year.

In cases where some of the goods covered by this article are disposed of, the cost to be charged shall be equal to the tax value assigned to them in the initial inventory for the period in which the sale is made. If investments have been made from the start of the exercise to the date of sale, the amount will be added, without updating, to the precited cost.

For the purpose of updating provided for in this article, the rates to be applied shall be those referred to in article 89.

Art. 56 - For the purpose of valuation of stocks of exchange goods, where it can be proved in a felicious manner that the cost in place of the goods, at the closing date of the period, is less than the amount determined in accordance with the provisions of articles 52 and 55, may be assigned to such property the cost in place, on the basis of the value arising from the evidentiary documentation. In order to make use of this option, the methodology used for the determination of the cost in place should be informed to the IMPOSITIVA GENERAL DIRECTION, at the time of the presentation of the affidavit corresponding to the fiscal year in which the cost had been used for the valuation of the aforementioned stocks.

Art. 57 - When the taxpayer withdraws for his or her particular use or for his or her family or disposes of goods from his or her business to activities whose results are not achieved by the tax (recree, stud, donations to non-exempt persons or entities, etc.), for the purposes of this tax, such acts shall be deemed to be carried out at the price obtained in onerous operations with third parties.

The same treatment will be to dispense with the operations carried out by a company on behalf of its partners.

Art. 58 - When movable goods are disposed of, the gross profit will be determined by deducting from the sale price, the computable cost established according to the rules of this article:

(a) Property acquired:

The cost of acquisition, updated from the date of purchase to the date of disposal, shall be subtracted the amount of ordinary amortizations, calculated on the updated value, in accordance with article 84, item 1, relating to the periods of useful life elapsed or, where appropriate, the amortizations applied under special rules.

(b) Goods developed, manufactured or built:

The cost of processing, manufacturing or construction will be determined by updating each of the amounts invested from the date of investment to the date of completion of the development, manufacture or construction. To the amount thus obtained, updated from this last date to the disposal, the amortizations calculated in the manner provided for in the preceding paragraph shall be subtracted.

(c) Goods of exchange that are affected as goods of use:

The same procedure shall be used as that set out in subparagraph (a), considering as the acquisition value the tax value assigned to the exchange asset in the initial inventory for the period in which the impact was made and as the date of purchase of the beginning of the exercise. When goods are affected not included in the initial inventory, the cost of the first purchased in the period will be taken as the acquisition value, in which case the update will be applied from the date of the purchase.

Subjects who are required to perform the inflation adjustment set out in Title VI, to determine the computable cost, will update the costs of acquisition, processing, investment or impact to the date of the end of the period prior to the one in which the disposal is made. In addition, when goods have been disposed of in the same period as the date of disposal, for the purpose of determining the computable cost, they shall not update the purchase value of the aforementioned goods. These provisions will be applicable if the conditions provided for in the last two paragraphs of article 95 of this Act are verified. If such conditions are not met, the provisions set out in the preceding paragraph shall apply. (For the last paragraph replaced by art. 37 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

For the purpose of the update referred to in this article, the indexes referred to in article 89 shall apply.

Art. 59 - Where real property is disposed of which is not of the nature of exchange property, the gross profit shall be determined by deducting from the sale price, the computable cost resulting from the application of the rules of this article:

(a) Real estate:

The cost of acquisition - including the costs required to carry out the operation - updated from the date of purchase to the date of disposal.

(b) Real estates built:

The cost of construction will be established by updating each of the investments, from the date the investment was made to the date of completion of the construction.

The value of the land determined according to subparagraph (a) will be added to the updated construction cost from the date of completion of the construction to the date of disposal.

(c) Construction:

The value of the land determined according to subparagraph (a), plus the amount resulting from updating each of the investments from the date they were made to the date of disposal.

If improvements have been made on the assets disposed of, the value of the assets will be established by updating the amounts invested from the date of investment to the date of completion of the improvements, computing as a cost such value, updated from the date of completion to the date of disposal. In the case of ongoing improvements, the cost will be established by updating investments from the date of disposal of the asset.

In cases where the assets disposed of have been affected by activities or investments resulting from the results achieved by the tax, the amounts obtained in accordance with the above paragraphs shall be restricted to the amount resulting from the application of the amortizations referred to in article 83 for the periods in which the assets were affected.

Where the alien is a subject bound to make the inflation adjustment established in Title VI, the provisions of the penultimate paragraph of Article 58 shall apply.

The update provided for in this article shall be carried out using the indexes mentioned in article 89.

Art. 60 - When keys, brands, patents, concession rights and other similar assets are disposed of, the gross profit shall be determined by deducting from the sale price the acquisition cost updated by applying the indexes mentioned in Article 89, from the date of purchase to the date of sale. The amount thus obtained will be reduced in the repayments to be applied, calculated on the updated value.

In cases where the alien is a subject that must perform the inflation adjustment established in Title VI, the provisions of the penultimate paragraph of Article 58 shall apply.

Art. 61 - When social shares, shares or shares are disposed of, including shares of common investment funds, the gross gain shall be determined by deducting from the transfer price the updated acquisition cost, by applying the indexes mentioned in article 89, from the date of acquisition to the date of transfer. In the case of released shares it will be taken as acquisition cost its updated nominal value. To this end, it shall be considered, without admitting evidence to the contrary, that the alienated assets correspond to the oldest acquisitions of their same species and quality.

In cases where actions received from 11 October 1985 are transferred, such as free or unconsidered dividends for the purposes of the levy, no cost will be computed.

The provisions of this article will also apply to representative values and certificates of deposit of shares and other values, certificates of participation of financial trusts and any other right on trusts and similar contracts. (Last paragraph incorporated by art. 38 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Where the alien is a subject that must perform the inflation adjustment established in Title VI, the provisions of the penultimate paragraph of Article 58 shall apply.

Art. 62 - Where signs or advances have been delivered at a price freeze, prior to the date of acquisition of the assets referred to in articles 58 to 61, the amount of updates to those concepts, calculated by the application of the indexes referred to in article 89, from the date on which they have been made effective to the date of acquisition, shall be added.

Art. 63 -When digital currencies, Public titles, bonds and other values are disposed of, the cost to be charged shall be equal to the tax value assigned to them in the initial inventory for the period in which the disposal is made. If it were acquisitions made in the year, the computable cost will be the purchase price. (Paragraph replaced by art. 39 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

In its case, it will be considered without admitting evidence to the contrary that the alienated assets correspond to the oldest acquisitions of their same species and quality.

Art. 64 - The dividends, as well as the distributions in stocks from revalues or accounting adjustments will not be computed by their beneficiaries for the determination of their net profit.

For the purposes of the determination of the same shall be deducted - with the limitations established in this law - all the expenses necessary to obtain the benefit, provided that they had not already been considered in the liquidation of this tax.

Equal treatment will have the utilities that the subjects covered by Article 69, paragraphs 2, 3, 6, 7 and 8 (a), distribute to their partners, members, trustees, beneficiaries or shareholders. (Last paragraph replaced by art. 40 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

(Article replaced by Act No. 25.063, Title, art.4°, subparagraph ñ. - Proceeding: From its publication in the Official Gazette and effect will be given to the periods that close after the entry into force of this law or, if any, the current fiscal year to that date. )

Art. 65 - When profits come from the disposal of goods other than exchange goods, immovable property, immaterial goods, shares, representative values and certificates of deposit of shares and other values, quotas and social shares .including shares of common investment funds and certificates of participation of financial trusts and any other rights on trusts and similar contracts ,, digital currencies, securities, acquisitions,

(Article replaced by art. 41 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Art. 66 - When any of the amortizable properties, except the properties, will be out of use (unused), the taxpayer may choose to continue to amortize it annually until the total extinction of the original value or to impute the difference between the amount not yet amortized and the sale price, in the tax balance of the year in which it is made.

The rules on the adjustment of amortization and the value of the assets contained in articles 58 and 84 shall be applicable as appropriate.

Art. 67 - In the event of the replacement and disposal of a compensable piece of goods, it may be opted to impute the profit of the disposal to the tax balance or, if not, to affect the profit to the cost of the new good, in which case the amortization provided for in Article 84 must be practiced on the cost of the new good decreased in the amount of the affected profit.

This option will also apply when the replaced asset is a property affected to the exploitation as a good of use or affected to the location or lease or to onerous assignments of usufruct, use, room, anticresis, surface or other real rights, provided that such destination has, at least, an antiquity of two (2) years at the time of disposal and to the extent that the amount obtained in the disposal is reinvested in the previous good of (Paragraph replaced by art. 42 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

The option to affect the benefit to the cost of the new good will only proceed when both operations (sales and replacement) are performed within the term of UN (1) year.

Where, in accordance with the provisions of this law or its regulatory decree, it is appropriate to impute to the exercise profits in a timely manner affected to the acquisition or construction of the property or replacement goods, the respective amounts must be updated using the update index mentioned in article 89, referring to the month of the closing of the fiscal year in which the affected profit was determined, according to the table elaborated by the IMPOSITIVA GENERAL DIRECTION for the month of the closing of the fiscal year.

Art. 68 - To account for foreign currency operations, a uniform system should be followed and the exchange rates to be used will be those that set the rules for each type of operation. The exchange differences shall be determined by annual revaluation of the unpaid balances and between the last valuation and the amount of the total or partial payment of the balances, and shall be charged to the annual tax balance.

CAPITAL SOCIEDADES

TASAS

Other

Art. 69 Capital societies, for their net taxable profits, are subject to the following rates:

(a) to twenty-five per cent (25%):

1. Anonymous companies .including single-personal anonymous companies,, companies in comandita for shares, in the part corresponding to the commissary partners, and societies for simplified actions of Title III of Law 27,349, incorporated in the country.

2. Limited liability companies, single-comandied societies and the share of the comandited partners of the companies in comandite for shares, in all cases in the case of companies constituted in the country.

3. The associations, foundations, cooperatives and civil and mutual entities, constituted in the country, as soon as this law does not correspond to another tax treatment.

4. Mixed economy societies, on the part of non-tax profits.

5. The entities and agencies referred to in article 1 of Act No. 22,016, not covered by the preceding paragraphs, as soon as there is no other tax treatment under article 6 of the Act.

6. Trusts constituted in the country in accordance with the provisions of the Civil and Commercial Code of the Nation, except those in which the fiduciant possesses the quality of beneficiary. The exception set out in this paragraph shall not be applicable in the cases of financial trusts or when the trustee-beneficiary is a subject covered by Title V.

7. Common funds of investment constituted in the country, not covered by the first paragraph of Article 1 of Law 24.083 and its amendments.

8. The societies included in article 49 (b) and the trustees covered by subparagraph (c) of the same article which elect to pay tribute in accordance with the provisions of this article. Such an option may be exercised as long as those concerned carry accounting records that allow them to make trade balances and shall be maintained for the period of five (5) fiscal periods from the first period in which the option is applied.

The subjects mentioned in paragraphs 1 to 7 above are covered by this paragraph from the date of the founding or holding of the respective contract, as appropriate, and for the subjects mentioned in paragraph 8, from the first day of the fiscal year following the exercise of the option.

(b) Twenty-five percent (25%):

Deriving from permanent establishments defined in the article without an aggregate number following article 16.

Such establishments must enter the additional rate of 13 per cent (13%) at the time of remission of profits to their parent household. (First paragraph of the article replaced by article 43 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

However, the rents derived from the exploitation of gambling in casinos (rule, point and banking, blackjack, poker and/or any other authorized game) and from the realization of bets through electronic gambling machines and/or automated bets (immediate resolution or not) and/or through digital platforms will tax forty-one eat fifty percent (41.50%). The aforementioned liquota will apply to both human and legal persons. (Convention by art. 1 p. 3 of the Act No. 27.346 B.O. 27/12/2016. Proceedings: from publication in the Official Gazette and effect for current fiscal exercises on the date of entry into force of the Reference Act.

The Federal Public Income Administration, an autonomous entity within the Ministry of Finance and Public Finance, shall establish the operating conditions for the application of this liquor and for the appropriation of expenses incurred in order to obtain, maintain and retain taxable gains referred to in the preceding paragraph, in accordance with the first paragraph of Article 80 of this Law. (Convention by art. 1 p. 3 of the Act No. 27.346 B.O. 27/12/2016. Proceedings: from publication in the Official Gazette and effect for current fiscal exercises on the date of entry into force of the Reference Act.

(Article replaced by Act No. 25.063, Title III, art.4°, subparagraph (o). - Proceeding: From its publication in the Official Gazette and effect will be given to the periods that close after the entry into force of this law or, if any, the current fiscal year to that date. )

Art. ... - Where the subjects covered in article 69, subparagraphs 1,2,3,6 and 7 (a), as well as those referred to in subparagraph (b) of the same article, make dividend payments or, where appropriate, distribute profits, in money or in kind, exceeding the specified profits based on the application of the general rules of this law, accumulated at the end of the immediate period prior to the date of such payment, shall retain one hundred and one hundred per cent.

For the purposes of the preceding paragraph, the gain to be considered in each exercise shall be that which results from detracting to the determined profit based on the application of the general rules of this law, the tax paid by the or the fiscal periods of origin of the profit that is distributed or the corresponding proportional part and summarizing the dividends or profits from other non-computed companies in the determination of such gain in the same fiscal periods.

In the case of dividends or profits in kind, the income of the indicated retention shall be made by the subject performing the distribution or the payment agent, without prejudice to his right to require the refund by the beneficiaries and to defer the delivery of the goods until the regime is effective.

The provisions of this article shall not apply to financial trusts whose certificates of participation are placed by public tender, in cases and conditions established by the regulation.

(Article 69 by Article 69 Act No. 25.063, Title III, art.4°, subparagraph (p). - Proceeding: From its publication in the Official Gazette and effect will be given to the periods that close after the entry into force of this law or, if any, the current fiscal year to that date. )

(Note Infoleg: by art. 83 of the Act No. 27.430 B.O. 29/12/2017 states that the provisions provided for in the first article without an aggregate number following article 69 of the Gain Tax Act, a text ordered in 1997 and its amendments, will not be applicable to dividends or profits attributable to accrued profits in fiscal years beginning on 1 January 2018. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

PRIVATE VALORES RETENTION

Art. 70 - (Article repealed by art. 80 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Art. 71 - (Article repealed by art. 80 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Art. 72 - When the arrangement of dividends or the distribution of profits, in kind, causes a difference between the current value in place at that date and its tax cost, relative to all the goods distributed under these conditions, the same shall be deemed to be the result of this tax and shall be included in the tax balance of the entity corresponding to the period in which the disposition or distribution takes place.

Art. 73 - Any provision of funds or assets made in favour of third parties by the subjects covered by article 49 (a), which does not respond to operations carried out in the interest of the company, shall presume, without admitting evidence to the contrary, a tax gain that shall be determined according to the following parameters:

(a) In the case of provision of funds, an annual interest equivalent to that established by regulation, according to each type, of currency shall be presumed.

(b) In respect of the dispositions of property, an annual gain of 8 per cent (8%) of the current value in the square of the real estate and 20 per cent (20%) of the current value in square relative to the rest of the property.

If payments are made during the same fiscal period for the use or enjoyment of such property, the amounts paid may be discounted for the purposes of this presumption.

The above provisions shall not apply in cases where such subjects make provisions of goods to third parties under market conditions, as provided by the regulations.

The treatment provided for in article 14, paragraphs 3 and 4, or in the first article added after article 46.

(Article 44 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

COMPANY OF CONSTRUCTION

Art. 74 - In the case of constructions, reconstructions and repairs of any kind to third parties, in which the profit-generating operations affect more than one fiscal period, the gross result of them must be declared according to one of the following methods, to the option of the taxpayer:

(a) Assigning to each fiscal period the resulting gross profit, on the amounts charged, the percentage of gross gain provided by the taxpayer for the entire work.

This coefficient may be modified - for the part for periods not yet declared - in case of evident alteration of what is foreseen when hiring.

The percentages referred to above are subject to the approval of the IMPOSTITIVE GENERAL DIRECTION.

(b) Assigning to each fiscal period the gross benefit resulting from deducting from the amount to be charged for all work performed in the same period, expenses and other determining elements of the cost of such work.

Where the determination of the benefit in the indicated form is not possible or is difficult, the brute utility contained in the building may be calculated according to a procedure similar to that indicated in subparagraph (a).

In the case of works that affect DOS (2) fiscal periods, but their total duration does not exceed one (1) year, the result may be declared in the period in which the work is finished.

La GENERAL DIRECTION IMPOSITIVA, if you consider it justified, may authorize equal treatment for those works that delay more than one (1) year, when such delay is motivated by special circumstances (wheel, lack of material, etc.).

In the cases of subparagraphs (a) and (b), the difference in more or less that is finally obtained, resulting from comparing the final gross utility of the entire work with that established by any of the procedures indicated in those paragraphs, shall affect the year in which the work is completed.

Choosing a method, the method must be applied to all works, works, etc., that the taxpayer does and cannot be changed without prior express authorization of the GENERAL IMPOSITIVA DIRECTION, which will determine from which fiscal period the method may be changed.

MINAS, CANTERAS AND BOSQUES

Art. 75 - The tax value of mines, quarries, forests and similar goods will be given by the share of the cost attributable to the mines, plus, where appropriate, the costs incurred to obtain the concession.

Where the exploitation of such goods is carried out in a manner involving the consumption of the income-producing substance, the deduction proportionately shall be admitted to the depletion of such substance, calculated according to the units extracted. The regulation may, taking into account the characteristics and nature of the activities referred to in this article, provide an update rate applicable to such deduction.

They are part of the tax value of mines, quarries, forests and similar goods referred to in the first paragraph of this article, the costs of meeting the technical and environmental requirements of the concessionaire and/or permissionary, as required by the applicable regulations issued by the competent enforcement authority. Such costs should be included from the time of the origin of the above-mentioned technical and environmental obligations in accordance with the current regulations, regardless of the period in which the erogations are made. (Third paragraph incorporated by art. 45 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

La GENERAL IMPOSTITIVE DIRECTION may authorize other systems to consider such exhaustion provided they are technically justified.

Art. 76 - Where the taxpayer ' s elements are not feasible to determine gross profit in the exploitation of natural forests, the IMPOSTITIVE GENERAL DIRECTION will set the applicable gross profit coefficients.

REORGANIZATION OF SOCIEDADES

Art. 77 - When companies, trade funds and companies and/or exploitations of any kind are reorganized in the terms of this article, the results that may arise as a result of the reorganization will not be reached by the tax of this law, provided that the or the continuing entities continue, for a period not less than DOS (2) years from the date of reorganization, the activity of the restructured or other companies associated with the same.

In such cases, the fiscal rights and obligations set out in the following article, relating to the subjects reorganised, shall be transferred to the continuing entity or entities.

The change of activity before the end of the specified period will have a resolute effect. The reorganization shall be communicated to the IMPOSTITIVE GENERAL DIRECTION within the time and conditions established by it.

In the event of failure to comply with the requirements established by this law or its regulatory decree for the reorganization to have the expected tax effects, the respective affidavits must be presented or rectified by applying the legal provisions that would have been appropriate if the operation had been carried out outside the present regime and the tax should be entered with more the update provided for in Act No. 11.683, without prejudice to the relevant interests and other accessories.

When the type of reorganization does not result in the total transfer of the reorganised companies, except in the case of excision, the transfer of tax rights and obligations shall be subject to the prior approval of the IMPOSTIVE GENERAL DIRECTION.

It is understood by reorganization:

(a) The merger of pre-existing companies through a third that is formed or by absorption of one of them.

(b) The excision or division of one company into another or others that continue the operations of the first.

(c) The sales and transfers from one entity to another that, despite being legally independent, constitute the same economic set.

In cases of other sales and transfers, the fiscal rights and obligations set forth in the following article shall not be transferred, and when the transfer price allocated is higher than in the square of the respective goods, the value to be considered impositively will be such price of the square, the treatment given by this law to the key item must be dispensed to the surplus.

In order for the reorganization to have the tax effects provided for in this article, the holders of the ancestors or companies shall maintain for a period not less than two (2) years from the date of the reorganization, an amount of participation not less than that which they must have at that date in the capital of the or the continuous companies, according to what, for each case, establishes the regulation. (Párrafo incorporated by Act No. 25.063, Title III, art.4°, subparagraph (r). - Proceeding: From its publication in the Official Gazette and effect will be given to the periods that close after the entry into force of this law or, if any, the current fiscal year to that date. )

The requirement in the preceding paragraph shall not be applicable when the or the continuous companies collect their shares in commercially self-regulated markets, having to keep that quote for a period not less than two (2) years counted from the date of reorganization. (Párrafo incorporated by Act No. 25.063, Title III, art.4°, subparagraph (r). - Proceeding: From its publication in the Official Gazette and effect will be given to the periods that close after the entry into force of this law or, if any, the current fiscal year to that date. )

Notwithstanding the provisions of the preceding paragraphs, the accumulated non-prescriptive tax breaks and the remaining tax franchises, originated in the placement of special promotion regimes, which refer respectively to Article 78 (1) and (5), shall be transferred only to the continuing enterprises, when the holders of the previous bureaux or the previous enterprises have retained the less than eighty years. (Párrafo incorporated by Act No. 25.063, Title III, art.4°, subparagraph (r). - Proceeding: From its publication in the Official Gazette and effect will be given to the periods that close after the entry into force of this law or, if any, the current fiscal year to that date. )

The limitations referred to in the preceding paragraphs shall not be applicable in the case of reorganizations produced in the context of a concursal process and/or reorganization is authorized by the Federal Public Income Administration, as a means of ensuring the continuity of business exploitation. (Párrafo incorporated by Act No. 25.063, Title III, art.4°, subparagraph (r). - Proceeding: From its publication in the Official Gazette and effect will be given to the periods that close after the entry into force of this law or, if any, the current fiscal year to that date. Note: Paragraph observed by the Executive Power by Decree No. 1.517/98.)

Art. 78 - The transferable tax rights and obligations to the continuing enterprises, in the cases provided for in the previous article, are:

(1) Unprescribed, accumulated tax breaks.

(2) Unpaid balances resulting from positive inflation adjustments.

(3) Unused tax franchise balances or special deductions due to limitations on the computable amount in each fiscal period and which were transferred to future periods.

(4) Deferred charges that had not been deducted.

(5) The unexploited tax franchises to which the predecessors or companies had been entitled, by virtue of the placement of special promotional regimes, as long as the basic conditions for granting the benefit are maintained in the or the new enterprises.

The implementing agency designated in the respective provision should be issued for this purpose.

6) The tax valuation of the goods of use, exchange and immaterial, regardless of the value assigned for the purposes of the transfer.

7) Reimbursements to the tax balance as a result of the sale of goods or decrease of stocks, when the use of franchises has been made or the tax revaluation of goods by the predecessor entities has been performed, in cases where the respective laws provide for it.

8) The systems of amortization of goods of use and immaterial.

9) The methods of imputation of profits and expenses per fiscal year.

10) The computation of the terms referred to in article 67, where tax treatment depends.

11) The systems of imputation of forecasts whose deduction authorizes the law.

If the transfer of the systems referred to in subsections 8), 9) and 11) of this article resulted in the use of different criteria or methods for similar situations in the new company, the new company must opt for one or the other of those followed by the predecessor companies, unless they relate to cases for which different treatments may be applied in the same company or exploitation.

In order to use criteria or methods other than those of the predecessor companies, the new company must apply for prior authorization to the IMPOSTITIVE GENERAL DIRECTION, provided that the legal or regulatory provisions require it.

CHAPTER IV GANANCIES OF THE FOURTH CATEGORY

INCOME OF PERSONAL WORK IN RELATION TO DEPENDENCE AND OTHER RENTS.

(Denomination replaced by art. 1 p. 4 Act No. 27.346 B.O. 27/12/2016. Vigencia: from its publication in the Official Gazette and will take effect from the fiscal year 2017, inclusive.

Art. 79 - Four-grade gains are made from:

(a) The performance of national, provincial, municipal and Autonomous City public officials, without exception, including the elective positions of the executive and legislative branches.

In the case of the Magistrates, Officials and Employees of the Judiciary of the Nation and of the provinces and the Public Ministry of the Nation when their appointment had occurred since 2017, inclusive. (Incision replaced by art. 1 p. 5 Act No. 27.346 B.O. 27/12/2016. Vigencia: from its publication in the Official Gazette and will take effect from the fiscal year 2017, inclusive.

(b) From personal work performed in relation to dependency.

(c) Retirements, pensions, withdrawals or subsidies of any kind as soon as they originate in personal work and to the extent that they have been subject to payment of the tax, and of the advisers of cooperative societies. (Incision replaced by art. 1 p. 5 Act No. 27.346 B.O. 27/12/2016. Vigencia: from its publication in the Official Gazette and will take effect from the fiscal year 2017, inclusive.

(d) Of the net benefits of non-deductible contributions, derived from compliance with the requirements of private retirement insurance schemes administered by entities subject to the control of FOLLOW-UP SUPERINTENDANCE, as soon as they originate in personal work.

(e) Of the personal services provided by the partners of the cooperative societies mentioned in the last part of Article 45 (g), who work personally in the exploitation, including the return received by them.

(f) From the exercise of liberal professions or trades and functions of albacea, yesndico, mandatario, manager of business, director of anonymous companies and trustee. (Paragraph replaced by art. 46 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

The amounts allocated as set out in the subparagraph are also considered as gains in this category.

(j) Article 87, to the managing partners of the limited liability companies, in simple comandite and in comandite for actions.

(g) The derivatives of brokerage, trade traveler and customs shipper.

Without prejudice to the other provisions of this law, for those who act in executive and executive positions of public and private companies, as established by the regulation, the sums that are generated solely on the basis of their dissociation of work, whatever their denomination, exceed the minimum compensatory amounts provided for in the applicable labour regulations. Where such amounts originate in a consensual agreement (processes of mutual agreement or voluntary withdrawal, among others) they shall be reached as soon as they exceed the minimum compensatory amounts provided for in the applicable labour regulations for the alleged dismissal without cause. (Second paragraph incorporated by art. 47 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

In addition, compensation in cash and in kind and in-kind as well as in-expenditure or reimbursement in this category shall be considered as proceeds by service commissions carried out outside the duty station, which are perceived for the exercise of the activities included in this article. (Paragraph replaced by art. 1 p. 6 of the Act No. 27.346 B.O. 27/12/2016. Vigencia: from its publication in the Official Gazette and will take effect from the fiscal year 2017, inclusive.

However, the deduction provided for in article 82 (e) of this law shall be applied, in the amount fixed by the Federal Public Income Administration, autarchic entity within the Ministry of Finance and Public Finance, on the basis of, among other parameters, the activity developed, the geographical area and the modalities of the provision of services, which shall not exceed the equivalent of forty per cent (40%) of the present income not attributable to the present paragraph. (Incorporated by substitution provided by art. 1 p. 6 of the Act No. 27.346 B.O. 27/12/2016. Vigencia: from its publication in the Official Gazette and will take effect from the fiscal year 2017, inclusive.

With regard to long-distance transport activities, the deduction indicated in the preceding paragraph may not exceed the amount of the unimposable gain set out in article 23 (a) of this Act. (Incorporated by substitution provided by art. 1 p. 6 of the Act No. 27.346 B.O. 27/12/2016. Vigencia: from its publication in the Official Gazette and will take effect from the fiscal year 2017, inclusive.

In addition, the amount paid to teaching staff for additional educational materials exceeding forty per cent (40 per cent) of the unimposable gain set out in article 23 (a) of this Act shall also be considered as gains in this category. (Incorporated by substitution provided by art. 1 p. 6 of the Act No. 27.346 B.O. 27/12/2016. Vigencia: from its publication in the Official Gazette and will take effect from the fiscal year 2017, inclusive.

To this end, the Federal Public Income Administration shall establish the conditions under which the compute of this deduction shall be effective. (Incorporated by substitution provided by art. 1 p. 6 of the Act No. 27.346 B.O. 27/12/2016. Vigencia: from its publication in the Official Gazette and will take effect from the fiscal year 2017, inclusive.

PART III

DEDUCTION

Art. 80 - The deduction expenses of this law, with the express restrictions contained therein, are those incurred to obtain, maintain and retain the proceeds encumbered by this tax and will be subtracted from the proceeds produced by the source that originates them. Where expenditures are incurred for the purpose of obtaining, maintaining and retaining taxable, exempt and/or unencumbered gains generated by different sources of production, deduction shall be made from the gross proceeds produced by each of them in the respective portion or proportion. When they measure practical reasons, and provided that this does not alter the amount of the tax to be paid, it will be admitted that the total of one or more expenses will be deducted from one of the sources of production.

(Article replaced by art. 48 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Art. ... - The expenses incurred in the Argentine Republic are presumed to be linked to gains from Argentine sources. Without prejudice to the provisions of article 87 (e) of the Act, expenses incurred abroad are presumed to be linked to foreign proceeds. However, their deduction from Argentine sources may be admitted if it is properly demonstrated that they are destined to obtain, maintain and retain profits from this origin.

(Article s/n incorporated after Article 80, by Article 49 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Art. 81 - From the profit of the fiscal year, whatever the source of profit and with the limitations contained in this law, it may be deduced:

(a) The interests of debts, their respective updates and the expenses originated by the constitution, renewal and cancellation thereof.

In the case of natural persons and indivisous successions, the causal relationship provided for in article 80 shall be established in accordance with the principle of property involvement. The concepts referred to in the preceding paragraph will be deductible only when it can be shown that they originate from debts incurred by the acquisition of goods or services that affect the acquisition, maintenance or maintenance of encumbered profits. No deduction shall be made in the case of tax gains which, in accordance with the provisions of this law, pay the retention tax on a single and definitive basis.

Notwithstanding the provisions of the preceding paragraph, the subjects indicated in the same paragraph may deduct the amount of interest in mortgage credits that have been granted to them by the purchase or construction of property destined to the taxpayer's room, or the causator in the case of indivisous successions, up to the sum of pesos twenty thousand ($ 20,000) per year. In the case of condominium properties, the amount to be deducted by each condomino may not exceed the amount resulting from the application of the percentage of its participation on the previously established limit.

In the case of the subjects covered by article 49, the interest of debts of a financial character consecuenciaexcluding, therefore, the debts generated by acquisitions of goods, locations and services related to the turn of the business contraído contracted with subjects, residents or not in the Argentine Republic, linked in the terms of the article incorporated in the following article 15 of this law, will be deductible from the tax balance to which its annual taxation corresponds, (Paragraph replaced by art. 50 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

The applicable limit referred to in the preceding paragraph may be added to the excess accumulated in the three (3) previous immediate fiscal periods, for being less than . in any of those periods. the amount of interest actually deducted from the applicable limit, to the extent that such surplus had not been applied prior to the procedure set out in this paragraph. (Paragraph replaced by art. 50 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Interests that, in accordance with the preceding paragraphs, could not be deduced may be added to those for the following five (5) immediate fiscal periods, subject to the limitation mechanism therein. The fourth paragraph of this subparagraph shall not apply in the following cases:

1. For entities governed by law 21.526 and its amendments.

2. For the financial trusts constituted in accordance with the provisions of articles 1,690 to 1,692 of the Civil and Commercial Code of the Nation.

3. For companies whose main purpose is to conclude leasing contracts in the terms, conditions and requirements set out in articles 1.227 et seq. of the Civil and Commercial Code of the Nation and in secondary form carry out exclusively financial activities.

4. For the amount of interest that does not exceed the amount of active interest.

5. Where it is established that, for a fiscal period, the relationship between the interests subject to the limitation of the fourth paragraph of this subparagraph and the net gain to which it is referred is less or equal to the ratio that, in that fiscal period, the economic group to which the subject in question belongs possesses by liabilities contracted with independent creditors and their net gain, determined in a manner similar to the provisions of the regulation; or

6. Where the regulation is proved to be fruitful, the beneficiary of the interests referred to in the fourth paragraph would have effectively taxed the tax on such rents, in accordance with this law. (Paragraph replaced by art. 50 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Interests shall be subject, at the time of payment, to the existing retention rules issued by the Federal Public Income Administration, irrespective of whether they are deductible. (Paragraph replaced by art. 50 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

For the purposes set out in paragraphs 4 to 7 of this subparagraph, the term "self-interests" also includes the differences in change and, if any, updates generated by the liabilities that originate them, to the extent that the procedure provided for in article 95 of this Act is not applicable, in accordance with the provisions of its second paragraph. The regulation may determine the inapplicability of the limitation provided for in the fourth paragraph when the type of activity carried out by the subject so warrants. (Paragraph incorporated by art. 50 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

(paragraph (a) replaced by article 4 of the Act No. 25.784B.O. 22/10/2003. - Watch: From the day of publication in B.O.)

(b) The sums paid by the intakers and insured by:

(i) death insurance; and

(ii) Mixed insurance .except for cases of private retirement insurance administered by entities subject to the control of the Superintendency of National Insurances—, in which the premiums covering the risk of death and the savings premiums will be deductible.

In addition, the amounts for the acquisition of shares of common investment funds that are constituted for withdrawal purposes shall be deductible in the terms of the regulation issued by the National Securities Commission and in the limits applicable to the deductions provided for in points (i) and (ii) of this subparagraph (b). (First paragraph replaced by art. 51 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Please note that the sum of CUATRO CENTAVOS DE PESO ($ 0.04) per year may be deducted by the concepts indicated in this paragraph, whether it is a single premium.

Excesses of the maximum amount mentioned above shall be deductible in the years of the insurance contract after the payment, to cover the total paid by the insured, taking into account, for each fiscal period, the aforementioned maximum limit.

The deduction amounts to be deferred will be updated by applying the update index mentioned in article 89, referring to the month of December of the fiscal period in which the expenditure was incurred, according to the table elaborated by the IMPOSITIVA GENERAL DIRECTION for the month of December of the fiscal period in which the deduction is appropriate.

(c) Donations to national, provincial and municipal fiscos, to the Permanent Partition Fund, to political parties recognized even in the case of electoral campaigns and to institutions, covered by article 20 (e), carried out under the conditions established by the regulation and up to the limit of five per cent (5%) of the net profit of the exercise. (First paragraph replaced by article 68 of the Act No. 26.215 B.O. 17/1/2007).

The above provisions shall also apply to the institutions covered by article 20 (f), the main objective of which is:

1. The conduct of social assistance or medical work in charity, non-profit, including child care and protection, old age, handicap and disability. (Apartment 1 replaced by art. 52 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

2. Scientific and technological research, even if it is intended for academic or teaching activity, and has a qualification certificate regarding research programmes, researchers and support staff participating in the corresponding programmes, extended by the SECRETARIAT OF SCIENCE AND TECHNOLOGY under the MINISTERY OF CULTURE AND EDUCATION.

3. Scientific research on economic, political and social issues aimed at the development of political party plans.

4. The systematic and graduated educational activity for the granting of titles officially recognized by MINISTERY OF CULTURA and EDUCATION, as well as the promotion of cultural values, through the sponsorship, subsidy, dictation or maintenance of free courses provided in public or private educational establishments recognized by the Ministries of Education or the like, of the respective jurisdictions.

(d) Contributions or discounts for retirement, retirement, pension or subsidies, provided that they are used in national, provincial or municipal funds.

(e) (Section repealed by art. 17 of the Act No. 26.425 B.O. 9/12/2008. Watch: from the date of publication in the Official Gazette.)

(f) The amortizations of immaterial goods that by their characteristics have a limited duration, such as patents, concessions and similar assets.

(g) Compulsory discounts for contributions to social works for the taxpayer and for those who review for the taxpayer the character of family charges.

In addition, the amounts paid in respect of contributions or contributions to institutions providing medical care, for the taxpayer and for persons reviewing the character of family charges, will be deductible. This deduction cannot exceed five percent (5%) of the net profit of the exercise. (Incision replaced by art. 53 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

(h) The fees for the health, medical and paramedical services of the taxpayer and of the persons who review for the taxpayer the character of family charges: (a) of hospitalization in clinics, sanatoriums and similar establishments; (b) the accessory benefits of hospitalization; (c) the services provided by doctors in all their specialties; (d) the services provided by biochemicals, dentists, kinesiologists

Deduction shall be admitted provided that it is effectively invoiced by the respective service provider and up to a maximum of forty per cent (40%) of the total invoice for the fiscal period concerned, provided that the amounts are not reached by refund systems included in medical coverage schemes. This deduction cannot exceed five percent (5%) of the net profit of the exercise. (Incision replaced by art. 53 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

(i) Forty per cent (40 per cent) of the sums paid by the taxpayer, or by the causator in the case of indivisous successions, for rentals of property destined to his house room, and up to the limit of the sum provided for in article 23 (a) of this law, provided that the taxpayer or the causator does not hold any property, regardless of the proportion.

The Federal Public Income Administration, an auto-archic entity within the Ministry of Finance and Public Finance, will establish the conditions under which the calculation of this deduction will be made effective. (Included by art. 1 p. 7 Act No. 27.346 B.O. 27/12/2016. Vigencia: from its publication in the Official Gazette and will take effect from the fiscal year 2017, inclusive.

(j) Contributions for private retirement insurance schemes administered by entities subject to the control of the National Insurance Superintendency. (Included by art. 54 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

In the case of donations to the Permanent Fund or to the recognized political parties, including those made for electoral campaigns, the limit established for its deduction should be calculated autonomously with respect to the rest of the donations. (Párrafo) incorporated by art. 41 of the Act No. 27.504 B.O. 31/5/2019. Watch: the following day of publication in the Official Gazette)

For the purpose of determining the limits set out in the first paragraph of subparagraph (c) and in the second paragraph of subparagraphs (g) and (h), such percentages shall be applied on the net gains of the exercise that result before deducting the amount of the concepts covered by the above-mentioned rules, that of previous years ' breaches and, where appropriate, the amounts referred to in article 23 of the Act. (Paragraph incorporated by art. 55 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

The national executive branch shall establish the maximum amounts deductible by the concepts referred to in subparagraphs (b) and (j). (Paragraph incorporated by art. 55 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

SPECIAL DEDUCTIONS OF CATEGORIES

FIRST, SECOND, THIRD AND FOURTH

Art. 82 - Of the gains of the first, second, third and fourth categories, and with the limitations of this law, may also be deduced:

(a) Taxes and fees on proceeding assets.

(b) Insurance premiums that cover risks on profitable goods.

(c) Extraordinary losses incurred by incident or force majeure in profit-producing assets, such as fires, storms or other accidents or accidents, were not covered by insurance or compensation.

(d) Duely substantiated losses, in the opinion of the IMPOSITIVE GENERAL DIRECTION, resulting from crimes committed against the exploitation of the taxpayers, by employees of the taxpayers, as soon as they are not covered by insurance or compensation.

(e) Mobility, road and other similar compensation costs in the amount recognized by the IMPOSITTIVE GENERAL DIRECTION.

(f) Remorse for wear, exhaustion or obsolescence and loss for disuse, in accordance with the provisions of the relevant articles, except those contained in article 88 (l). (Substituted decision by art. 56 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

In the cases of subparagraphs (c) and (d), the regulatory decree shall establish the incidence of deductions in the cost of the good.

Art. 83 - In the concept of amortization of buildings and other buildings on properties affected to activities or investments that originate results achieved by the tax, except for goods of change, it will be admitted to deduct the DOS per CIENTO (2 %) annual on the cost of the building or construction, or on the part of the acquisition value attributable to the same, taking into account the relationship existing in the tax assessment or, in its default, according to the fairness that is applied.

For the purposes of the calculation of the amortization referred to in the preceding paragraph, the same shall be practiced from the beginning of the quarter of the fiscal year or timetable in which the impact of the good had occurred, until the quarter in which the value of the goods is exhausted or until the immediate quarter prior to that in which the goods are disposed of or disabling of the activity or investment.

The resulting amount shall be adjusted in accordance with the procedure set out in article 84 (2).

La GENERAL IMPOSTITIVE DIRECTION may admit the application of annual percentages higher than DOS BY SCIENTY (2 %), when it is proved fervently that the useful life of the properties is less than CINCUENTA (50) years and provided that such a circumstance is communicated to the Agency, on the occasion of the submission of the affidavit corresponding to the first fiscal year in which they are applied.

Art. 84 - In the concept of annual tax amortization to compensate for the wear of the property - other than real estates - used by the taxpayer to produce taxable profits, it shall be admitted to deduct the amount resulting in the following rules:

(1) The cost or value of acquisition of the goods will be divided by a number equal to the probable years of useful life of the same. IMPOSTITIVE GENERAL DIRECTION may admit a different procedure (units produced, hours worked, etc.) when technical reasons justify it.

(2) The regular amortization fee calculated in accordance with the provisions of the preceding paragraph, or the taxpayer ' s amortization fee under special rules, shall be applied to the update index referred to in article 89, referring to the date of acquisition or construction indicating the table elaborated by the IMPOSTITIVE GENERAL DIRECTION for the month to which the date of closure of the fiscal period to be liquidated. The amount thus obtained will be the deductible annual amortization.

In the case of intangible property the sum to be deducted shall be determined by the application of the rules set out in the preceding paragraph.

For the purpose of determining the original value of compensable goods, the fees paid and/or accredited to entities of the same economic set, intermediaries in the purchase operation shall not be computed, unless an effective provision of services is proved for such purposes. (Paragraph 3 and 4 replaced by the current third paragraph by article 5 of the Act No. 25.784B.O. 22/10/2003. - Watch: From the day of publication in B.O.)

SPECIAL DEDUCTIONS OF FIRST CATEGORY

Art. 85 - The benefits included in the first category may also be deducted from the maintenance of the property. To this end, taxpayers shall opt for any of the following procedures:

(a) Deduction of actual expenditures based on vouchers.

(b) Deduction of the alleged costs resulting from the application of the CINCO coefficient per SCIENTO (5 %) on the gross income of the property, percentage that involves maintenance costs for all purposes (reparations, administration expenses, insurance premiums, etc.).

Adopted a procedure, the same shall apply to all the properties owned by the taxpayer and may not be varied by the term of CINCO (5) years, counted from the period, even when the option has been made.

The option referred to in this article may not be made by those individuals who by their nature must carry books or have administrators who must be aware of their management. In such cases, actual expenditures should be deducted from proof.

For rural properties, deduction will be made, in all cases, by the procedure of actual expenses checked.

SPECIAL DEDUCTIONS OF THE SECOND CATEGORY

Art. 86 - Beneficiaries of royalties resident in the country may make the following deductions, as appropriate:

(a) When royalties originate in the definitive transfer of goods - whatever their nature- the VEINTICINCO BY CIENTO (25 %) of the sums received by this concept, until the recovery of the capital invested, resulting to this end the provisions of articles 58 to 63, 65 and 75, according to the nature of the transferred good.

(b) Where royalties originate in the temporary transfer of goods that suffer from wear or exhaustion, the deduction of the amount resulting from the application of the provisions of articles 75, 83 or 84 shall be permitted, depending on the nature of the goods.

The above-mentioned deductions will be derived as long as the costs and expenses incurred in the country are concerned. In the event of costs and expenses incurred abroad, it will be admitted as the only deduction for any concept (recovery or amortization of the cost, expenses for the perception of profit, maintenance, etc.) the ACCOUNT FOR SIGN (40 %) of the royalties received.

The above standards will not be applicable when it comes to beneficiaries residing in the country who regularly carry out research, experimentation, etc., aimed at obtaining goods susceptible to producing royalties, who will determine the profit by application of the rules governing the third category.

SPECIAL DEDUCTIONS OF THIRD CATEGORY

Art. 87 - The gains of the third category and the limitations of this Act may also be deduced:

(a) The expenses and other erogations inherent in the turn of the business.

(b) Punishments and forecasts against bad credits in justifiable amounts according to the uses and customs of the bouquet. IMPOSITIVE GENERAL DIRECTION may establish rules on how to effect such punishment.

(c) Organizational expenses. IMPOSTITIVE GENERAL DIRECTION will admit its involvement in the first exercise or its amortization within a not greater period of CINCO (5) years, to the option of the taxpayer.

(d) The sums that insurance, capitalization and the like are intended to integrate the forecasts for mathematical reserves and reserves for current and similar risks, in accordance with the rules imposed on the subject by the SUPERINTENDANCE OF ASSESSMENT or other official dependence.

In all cases, forecasts for technical reserves for the previous year, which had not been used to pay sinisters, will be considered as gain and should be included in the taxable net profit of the year.

(e) The fees and expenses incurred abroad set out in article 8, as soon as they are fair and reasonable.

(f) (Subparagraph eliminated Act No. 25.063, Title III, art.4°, subparagraph (t). - Proceeding: From 31/12/98, the fiscal year 1998 will take effect. )

(g) Expenditure or contributions made to staff for health care, school and cultural assistance, subsidies to sports clubs and, in general, any expenditure on assistance for employees, dependants or workers. The gratifications, sprains, etc., which are paid to the staff within the time frames in which, according to the regulations, the affidavit must be submitted for the period.

La GENERAL DIRECTION IMPOSITIVA may challenge the part of the qualifications, gratifications, sprains, etc., which exceeds what is usually done by such services, taking into account the work carried out by the beneficiary, the importance of the company and other factors that may influence the amount of the retribution.

(h) Employers ' contributions to private retirement insurance schemes administered by entities subject to the control of the SUPERINTENDANCE OF FOLLOWERS and the plans and funds for retirements and pensions of mutual funds registered and authorized by the NATIONAL INSTITUTE OF COOPERATIONAL ACTION And MUTUAL, up to the sum of QUINCE PESO CENTAVOS ($ 0.15) per employee in relation to dependency included in retirement insurance or in retirement and pension plans and funds.

The amount set out in the preceding paragraph will be updated annually by the IMPOSTITIVE GENERAL DIRECTION, applying the update index mentioned in article 89, referring to the month of December 1987, as indicated in the table prepared by that Agency for each month of the closing of the fiscal period in which the deduction is appropriate.

In this paragraph, contributions to life insurance schemes containing savings accounts administered by entities subject to the control of the Superintendency of National Insurance and common investment funds constituting for retirement purposes are included in this paragraph, in the terms of the second paragraph of article 81 (b) of this Act. (Last paragraph incorporated by art. 57 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

(i) The actual and duly accredited representation costs, up to an amount equivalent to UNO CON CINCUENTA (1.50 per cent) of the total amount of remuneration paid in the fiscal period to staff in relation to dependency.

(Incision replaced by Act No. 25,239, Title I, art.1°, subparagraph (n). - Watch: From 31/12/99, the exercises starting from that date will take effect. )

(j) The amounts for the payment of fees to directors, trustees or members of the monitoring councils and those accorded to the administering partners - with the limitations set out in this paragraph - by the contributors included in article 69 (a).

The sums to be deducted in honor of directors and members of monitoring and retribution councils to the managing partners for their performance as such, may not exceed the VEINTICINCO per SCIENT (25 %) of the accounting profits of the year, or until the one that results from computing DOCE MIL QUINIENTOS PESOS ($ 12,500) for each of the taxpayers of the greater In the event of assignment after such a period, the amount that is computable in accordance with the above provisions shall be deductible in the period in which they are assigned.

The amounts that exceed the limit indicated will have for the beneficiary the treatment of non-computable for the determination of the tax, provided that the tax balance of the society imposed on the exercise by which the remunerations are paid.

(Third paragraph replaced by Act No. 25.063, Title III, art.4°, subparagraph (u). - Proceeding: From 31/12/98, the fiscal year 1998 will take effect. )

The reserves and forecasts that this law admits to deduct in the tax balance are subject to the tax in the exercise in which the risks covered are cancelled (reservation for dismissals, etc.).

DEDUCTIONS NOT ADMITTED

Art. 88 - They shall not be deductible, without distinction of categories:

(a) Personal and living expenses of the taxpayer and his family, except as provided for in articles 22 and 23.

(b) The interests of the capital invested by the owner or partner of the companies included in Article 49, subparagraph (b), such as the sums withdrawn on the basis of profits or on the basis of salary and any other concept that amounts to a withdrawal on profits account.

For the purposes of the tax balance, the amounts that had been deducted from the concepts included in the preceding paragraph should be added to the participation of the owner or partner to whom it is appropriate.

(c) The remuneration or salary of the spouse or relative of the taxpayer. When an effective service delivery is demonstrated, the remuneration paid in the party that does not exceed the retribution that is usually paid to third parties for the provision of such services shall be deducted, not exceeding the payment to the employee - not relative - of a higher category, except provision contrary to the IMPOSTITIVE GENERAL DIRECTION.

(d) The tax of this law and any taxes on wastelands and fields that are not exploited.

(e) Remuneration or salaries paid to members of directories, councils or other agencies acting abroad, and fees and other remuneration paid for technical-financial or other advice rendered from abroad, in amounts exceeding the limits set by regulation.

(f) The amounts invested in the acquisition of goods and on permanent improvements and other costs associated with such operations, except taxes that detract from the free transfer of goods. Such costs shall include the cost of assets for the purposes of this Act.

(g) The profits of the exercise that are intended to increase capital or reserves of the company whose deduction is not expressly permitted in this law.

(h) Key amortization, similar brands and assets.

(i) Donations not covered by article 81 (c), food benefits, or any other act of liberality in money or in kind.

(j) Losses generated by or linked to illicit operations, including erogations related to the commission of the crime of cohecho, including in the case of foreign public officials in international economic transactions. (Substituted decision by art. 58 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

(k) The benefits that societies should separate to constitute the legal reserve fund.

(l) The disused amortizations and losses referred to in article 82 (f), relating to cars and the rental thereof (including the derivatives of leasing contracts), to the extent that they exceed what would be appropriate to deduce with respect to cars whose cost of acquisition, import or value of place, if they are of own production or leased with option of purchase, be superior to the sum of VEINTE MIL

Nor shall the costs be deductible in fuels, lubricants, patents, insurances, ordinary repairs and in general all costs of maintenance and operation of cars other than exchange goods, as soon as they exceed the overall amount that, for each unit, is fixed annually by the General Tax Directorate.

The provisions of this subparagraph shall not apply to cars whose exploitation constitutes the main object of the encumbered activity (rent, taxis, remissions, traders and the like). (Incision replaced by Act No. 24.885, Chapter I, art. 1 - Watch: from 7/12/97.)

(Note: La Act No. 24.917Article 1 extends the entry into force of the substitution of this subparagraph, which shall govern from 1 January 1998. )

(m) Retributions for the exploitation of trademarks and patents belonging to foreign subjects, in amounts exceeding the limits established by the regulation. (Input input Act No. 25.063, Title III, art.4°, subparagraph (v). - Watch: From 31/12/98.)

ESTABLISHMENT

Art. 89 - The updates provided for in this Act shall be made in accordance with article 39 of Law 24.073.

Without prejudice to the provisions of the preceding paragraph, the updates provided for in Articles 58 to 62, 67, 75, 83 and 84, and in Articles 4 and 5o added after Article 90, regarding the acquisitions or investments made in the fiscal periods beginning on 1 January 2018, will be made on the basis of the percentage variations of the general consumer price index (IPC) that supply the Federal Statistics Tables. (Expression of domestic prices to wholesale (IPIM) is replaced by the expression "price index to the consumer general level (IPC), by art. 1 of the Act No. 27.468 B.O. 4/12/2018. Monitoring: the day of publication in the Official Gazette and will be effective for fiscal years or fiscal years initiated from 1 January 2018, inclusive)

(Article replaced by art. 59 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

PART IV

AND OTHER PROVISIONS

(Denomination of replaced Title by art. 60 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

CHAPTER I - PROGRESS.

(Instrumental Chapter Title by art. 61 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Art. 90 - Human persons and indivisous successions swhile there is no declaration of heirs or declared valid will that fulfills the same purpose las will pay on the net proceeds subject to tax the amounts that result according to the following scale: (Expression is a visible existence, replaced by shihumans. by art. 79 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Accumulated net gain		They'll pay $	More than %	About the $ surplus
More than $	A$
0	20.000	0	5	0
20.000	40.000	1,000	9	20.000
40.000	60,000	2.800	12	40.000
60,000	80,000	5.200	15	60,000
80,000	120.000	8.200	19	80,000
120.000	160,000	15.800	23	120.000
160,000	240,000	25,000	27	160,000
240,000	320,000	46.600	31	240,000
320,000	forward	71,400	35	320,000

(First paragraph replaced by article 1 p. 8 of the Act No. 27.346 B.O. 27/12/2016. Vigencia: from its publication in the Official Gazette and will take effect from the fiscal year 2017, inclusive.

The amounts provided for in this article will be adjusted annually, starting from the fiscal year 2018, even by the coefficient that arises from the annual variation of the Average Immuneration of Stable Workers (RIPTE), corresponding to the month of October of the year prior to the adjustment for the same month of the previous year. (Incorporated by substitution provided by art. 1 p. 8 of the Act No. 27.346 B.O. 27/12/2016. Vigencia: from its publication in the Official Gazette and will take effect from the fiscal year 2017, inclusive.

When the determination of the net profit of the subjects referred to in the first paragraph of this article, includes results included in Title IX of this law, from the disposal of shares, representative values and certificates of deposit of shares and other values, quotas and social participations sincluded shares of common funds of investment and certificates of participation of trusts and any other right on trusts, property bonds, etc. (Paragraphs third to sixth replaced by art. 62 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

When the determination of net income corresponds to extra hours obtained by workers in relation to dependency, the amounts resulting from such a concept, without including those set out in article 20 (z), shall not be computed for the purpose of modifying the scale set out in the first paragraph, so such emoluments shall tax by applying the corresponding marginal account, prior to the incorporation of extra hours. (Convention by art. 1 p. 9 of the Act No. 27.346 B.O. 27/12/2016. Vigencia: from its publication in the Official Gazette and will take effect from the fiscal year 2017, inclusive.

The Federal Public Income Administration shall determine the modalities for liquidation as set out in the preceding paragraph. (Convention by art. 1 p. 9 of the Act No. 27.346 B.O. 27/12/2016. Vigencia: from its publication in the Official Gazette and will take effect from the fiscal year 2017, inclusive.

(Note Infoleg: by art. 84 of the Act No. 27.430 B.O. 29/12/2017 states that the provisions provided for in the fifth paragraph of Article 90 of the Law on Taxation of Gains, a text ordered in 1997 and its amendments, introduced by Article 4 of Law 26.893, shall be applicable until the date of entry into force of this Law, to the extent that, with regard to the obligation referred to therein, the tax had been entered into that period. If the tax has not been entered, it will also result from, application except in the event that, in the case of the securities and securities markets authorized and/or with public tender authorization, the agents involved would not have retained or perceived it because of the absence of regulatory regulations that would force them to do so at the time of operations. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

(Instrumental chapter by art. 63 Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

ARTICLE... Performance from the placement of capital in values. The net gain of Argentinean source of humans and indivisous successions derived from results in terms of interest or the denomination that has the yield of the position of capital in the respective cases of values referred to in the fourth article without number alleged following article 90 que which is part of this Chapter,, or of interest originated in term deposits made in institutions subject to the regime of financial entities of the law will be reached by 21

(a) Bank deposits, Public titles, negotiable obligations, shares of common investment funds, titles of financial trust debt and similar contracts, bonds and other values, in national currency without adjustment clause: 5 per cent (5%).

The National Executive Power will be able to increase the liquota set out in the preceding paragraph of this paragraph, not exceeding that provided for in the following paragraph, provided that they report well-founded technical reports, based on economic variables, which justify this.

(b) Bank deposits, Public titles, negotiable obligations, shares of common investment funds, titles of financial trusts debt and similar contracts, bonds and other values, in national currency with adjustment clause or in foreign currency: fifteen percent (15%).

In the case of repurchase of shares of common investment funds of the first paragraph of Article 1 of Law 24.083, consisting of investments in the first paragraph of this Article in different currencies, the regulation may establish procedures that provide for the form of application of the rates, in proportion to the respective underlying assets.

The provisions of this article will also apply when the alien subject reviews the status of foreign beneficiary, who does not reside in non-cooperative jurisdictions or funds invested do not come from non-cooperative jurisdictions. In such cases the gain, to the extent that it is not, is exempt in accordance with the provisions of article 20, paragraph 4 (w), shall be reached by the provisions contained in article 93, to the liquors established in the first paragraph of this article.

ARTICLE - Intereses (or returns) and discounts or emission bonuses. For the purpose of determining the gain from values that compromise interests or returns, which fit in this Chapter II or Title IX of this Law, the following procedures shall apply:

(a) If the value is subscribed to or purchased at the residual nominal price, the interest to be devented will be charged to the fiscal year in which the payment is verified, the date to be made available or its capitalization, whichever occurs first, provided that the value foresees interest payments in terms of up to one year. In respect of payment periods exceeding one year, the interest shall be charged in accordance with the accrual of time. In the event of the disposal of the value, the subscription or acquisition price will be considered as its computable cost. If at the time of the alienation there were interest accrued from the date of payment of the last interest share (exchanged interest) that had not been encumbered at that time, such interests, on the option of the taxpayer, may be discriminated against from the disposal price.

(b) If a value is acquired, whether or not it is in stock exchanges or markets, containing interest from the issue or from the date of payment of the last interest share, the taxpayer may choose between (i) to consider the purchase price as a computable cost of the acquired value, or (ii) to discriminate the correct interest from the purchase price. To choose the second alternative, to the extent that interest is paid, made available or capitalized, what happens before, the interest subject to tax will be the difference between the amount made available or capitalized and the portion of the acquisition price attributable to the interest at the date of acquisition.

(c) If you subscribe or acquire a value that would have been issued under the pair, paying a net price of corrected interest, less than the residual nominal, the discount will receive the treatment applicable to the interests, having to be charged on the basis of your accrual in each fiscal year, from the month of subscription or acquisition until the month in which partial and/or total amortization occurs or even its disposal, which occurs before. The regulation shall establish cases where such procedure is not applicable, as well as the imputation mechanism in the event of partial withdrawals. With respect to the interests of the value, the provisions of the preceding subparagraph (a) apply. For purposes of determining the result by disposal, the subscription or acquisition price will be added to the discount that had been encumbered each year between the date of subscription or acquisition and the date of disposal.

(d) If a value is subscribed or acquired by paying a net price of corrected interest, higher than the residual nominal, for the purpose of determining the gravable portion of the paid interest, made available or capitalized, the taxpayer may choose to deduce that difference based on its accrual in each fiscal year, from the month of subscription or acquisition until the month in which partial and/or previous amortization occurs,

The regulation shall establish the imputation mechanism in the event of partial amortizations. With respect to the interests of the value, the provisions of the preceding subparagraph (a) apply. For purposes of determining the result by disposal, the cost of subscription or acquisition shall be reduced, if any, to the cost referred to in part one of this subparagraph (d) that would have been deducted each year between the date of subscription or acquisition and the date of disposal.

The options referred to in subparagraphs (b), (c) and (d) above should be exercised over all respective investments and maintained for five (5) years.

The imputation according to its accrual according to the time referred to in subparagraph (a) of the first paragraph of this article, as well as the proportional accrual mentioned in subparagraphs (c) and (d), imply that, in cases of foreign currency securities, the conversion to pesos of the respective concepts shall be made to the type of buyer exchange according to the last value of the Bank of the Argentine Nation as at 31 December of each year. In terms of adjustment clause values, such concepts will be calculated on the value of the updated capital to that date.

ARTICLE ... The net gain of human persons and indivisous successions, derived from the dividends and profits referred to in Article 46 and the first article added after the latter, shall pay tribute to the account of the thirteen per cent (13%), not resulting in application for the subjects who pay the rents referred to in the second paragraph of Article 69.

The tax referred to in the preceding paragraph shall be retained by the paying entities of the said dividends and profits. Such retention shall be the sole and definitive payment for human persons and indivisous successions residing in the Argentine Republic who are not registered in this tax.

When it comes to the common investment funds covered by the first paragraph of article 1 of Act No. 24,083 and its amendments, the regulation may establish regimes for the retention of the liquota referred to in the first paragraph, on the dividends and profits mentioned therein, which will distribute to its investors in the event of ransom and/or payment or distribution of profits.

When the dividends and profits referred to in the first paragraph of this article are paid to foreign beneficiaries, it shall be for those who pay them to make the relevant retention and to enter into the Federal Public Income Administration that percentage, as a single and definitive payment.

ARTICLE... - Exchange operations of shares, representative values and certificates of deposit of shares and other values, quotas and social participations .including shares of common funds of investment and certificates of participation in financial trusts and any other right on trusts and similar contracts,, digital currencies, Titles, bonds and other values. The net gain of Argentinean source of humans and indivisse successions derived from results from stock disposal operations, representative values and certificates of deposit of shares, quotas and social participations sincluding shares of common funds of investment and certificates of participation of financial trusts and any other right on trusts and similar contracts :, digital currencies, Titles, bonds and other values,

(a) Public titles, negotiable obligations, Debt titles, shares of common investment funds not covered by the following subparagraph (c), as well as any other title or bond and other values, in all cases in national currency without adjustment clause: 5 per cent (5%).

The national executive branch may increase the liquor set out in the preceding paragraph, not being able to exceed that provided for in the next subparagraph, provided that they measure technical reports based on economic variables, which justify it.

(b) Public titles, negotiable obligations, Debt titles, shares of common investment funds not included in the following subparagraph (c), digital currencies, as well as any other title or bond and other values, in all cases in national currency with adjustment clause or in foreign currency: fifteen per cent (15 per cent).

(c) Actions, representative values and certificates of deposits of shares and other values, certificates of participation of financial trusts and any other right on trusts and similar contracts and shares of condominium of common funds of investment referred to in the second paragraph of Article 1 of Law 24.083 and its modifications, which (i) quote in exchanges or stock markets authorized by the National Securities Commission that do not meet the requirements of 20

In the case of shares of common investment funds covered by the first paragraph of Article 1 of Law 24.083 and/or certificates of participation of the financial trusts, whose main underlying asset is: (i) shares and/or values representative or certificates of participation in shares and other values, which meet the conditions referred to in Article 20(w) of the law, as well as (ii) values referred to in that claim,

In the case of operations for the rescue of shares of common investment funds of the first paragraph of Article 1 of Law 24.083 and/or of certificates of participation of financial trusts, composed of values covered by the first paragraph of this Article in different currencies, the regulation may establish procedures that provide for the form of application of the liquors referred to in the first paragraph, in proportion to the respective underlying assets,

Gross gain from disposal shall be determined on the basis of the following guidelines:

(i) In cases of the values covered by subparagraphs (a) and (b) of the first paragraph of this article, deducting the cost of acquisition from the transfer price. If these are national currency values with adjustment clause or foreign currency, updates and exchange differences will not be considered as members of the gross profit.

(ii) In the case of the values contained in paragraph 1 (c) of this article, deducting from the transfer price the updated acquisition cost, by applying the index mentioned in paragraph 2 of Article 89, from the date of acquisition to the date of transfer. In the case of actions released, the cost of acquisition shall be taken as the one referred to in the fourth paragraph of Article 46. To this end, it will be considered, without admitting proof to the contrary, that the alienated values correspond to the oldest acquisitions of their same species and quality.

The provisions of this article will also apply when the alien subject reviews the status of foreign beneficiary, who does not reside in non-cooperative jurisdictions or funds invested do not come from non-cooperative jurisdictions. In this case the profit gananciaincluding the one referred to in the article added without number following article 13 of this law— shall be reached by the provisions contained in subparagraph (h) and in the second paragraph of article 93, to the liquota in question established in the first paragraph of this article.

In cases, including the case covered by the article added without a number following article 13 of this law, in which the acquirer is not resident in the country, the tax must be entered by the foreign beneficiary through his legal representative domiciled in the country. For this purpose, the relevant legal instrument, established in the first paragraph of this article on the determined profit in accordance with the provisions of this law, shall be applied.

(Note Infoleg: See Table established by art. 2° Decree No. 279/2018 B.O. 9/4/2018 in relation to the items provided for in the fourth incorporated article without number following article 90 of the Law on Taxation of Gains, text ordered in 1997 and its amendments. Watch: the day after your publication in the Official Gazette)

ARTICLE... Disposal and transfer of property rights. The gain of human persons and of the indivisous successions derived from the alienation of or transfer of rights over, properties located in the Argentine Republic, will tax the liquor of fifteen percent (15%).

Gross gain will be determined on the basis of the following guidelines:

(a) Deducting from the disposal or transfer price the acquisition cost, updated through the application of the index mentioned in the second paragraph of Article 89, from the date of acquisition to the date of disposal or transfer. In the event that the property had been affected by the obtaining of results obtained by the tax, the amount obtained in accordance with the above provisions shall be subtracted from the amount of the admitted amortizations that would have been computed in a timely manner and those resulting up to the immediate quarter prior to that in which their disposal is appropriate.

(b) In cases of term operations, the gain generated on the basis of deferral and/or funding shall be treated in accordance with the applicable provisions of this law.

Costs (commissions, fees, taxes, fees, etc.) may be computed directly or indirectly related to the operations referred to in this article.

- Special deduction. Where human persons and indivisous successions resident in the country, obtain the gains referred to in the first article added without a number following article 90 and subparagraphs (a) and (b) of the first paragraph of the fourth article added without a number following article 90, as long as the proceeds of Argentine source are concerned, a special deduction may be made in the amount equivalent to the amount referred to in article 23 (a), for a tax period.

The calculation of the amount referred to in the preceding paragraph may not result in breach and may not be considered in subsequent fiscal periods, if any, the remaining unused.

In addition to the provisions of the first paragraph of this article, the acquisition costs and expenditures directly or indirectly related to them may be computed only against the profits mentioned in this Chapter, and the concepts provided for in articles 22, 23 and 81 of the Act and all those that do not correspond to a particular category of profits cannot be deduced.

ARTICLE... For the purpose of determining the gains referred to in this Chapter II, in all that is not specifically regulated by this Chapter, the provisions of Titles I and II of the Law shall be applied supplementally.

PART V

BENEFITS OF EXTERIOR

Art. 91 - When net profits of any category are paid to companies, companies or any other beneficiary of the outside - with the exception of dividends, the profits of the subjects referred to in paragraphs 2, 3, 6 and 7, of article 69 (a) and the profits of the establishments covered in subparagraph (b) of that article - it is incumbent upon those who pay them to return and enter the Federal Public Income Administration, entity to (Párrafo replaced by Act No. 25.063, Title III, art. 4°, subparagraph (e). - Watch: From 31/12/98.)

Payment is deemed to exist when some of the situations provided for in the last paragraph of article 18 are given, unless the benefit of companies covered by article 49 (b), in which case the provisions of article 50 shall apply.

In these cases it will be appropriate to practice the retention to the due date for the presentation of the tax balance, applying the rate of the TREINTA AND CINCO FOR SCIENTI (35 %) on the full profits that, according to the provisions of article 50, should be considered distributed to the partners who are beneficiaries of the outside. If between the closing date of the exercise and the above mentioned date the payment in the terms of Article 18 had been set up -total or partly - the indicated retention shall be made at the date of payment. (Tasa replaced by Act No. 25.063, Title III, art.4°, subparagraph (x). - Watch: From 31/12/98.)

The foreigner shall be deemed to be a beneficiary of the foreigner directly or through agents, agents, representatives or any other president in the country and to whom, by virtue of their profits in the country, shall not establish stable residence in the country. In cases where there is impossibility of retaining, the indicated income shall be borne by the paying entity, without prejudice to its rights to require the refund of part of the beneficiaries.

Art. 92 - Except in the case referred to in the third paragraph of Article 91, the retention provided for in Article 91 shall be established by application of the rate of TREINTA AND CINCO FOR SCIENTI (35 %) on the net profit presumed by this law for the type of profit in question. (Tasa replaced by Act No. 25.063, Title III, art.4°, subparagraph (x). - Watch: From 31/12/98.)

Art. 93 - Where external beneficiaries are paid in sums for the following concepts, net gain will be presumed, without being proven to the contrary:

(a) In the case of contracts that properly comply with the requirements of the Technology Transfer Act at the time of payment:

1. The SESENTA BY SCIENTO (60 %) of the amounts paid for benefits derived from technical assistance, engineering or consultancy services that were not obtained in the country in the opinion of the competent authority in the field of technology transfer, provided that they were properly registered and were effectively rendered.

2. OCHENTA BY CIENTO (80 %) of the amounts paid for benefits arising from the assignment of rights or licenses for the exploitation of invention patents and other objects not contemplated in point 1 of this paragraph.

3. (Point eliminated by Act No. 25.063, Title III, art.4°, subparagraph (z). - Watch: From 31/12/98.)

In the event that the same contract makes payments to which different percentages correspond, in accordance with points 1 and 2 above, the higher percentage shall apply.

(b) The TREINTA and CINCO (35 %) of the amounts paid in the case of exploitation in the country of copyright, provided that the respective works are duly registered in the NATIONAL DIRECTION OF THE RIGHT OF AUTOR and that the profits originate in the assumptions provided for in article 20 (j) and that the requirements of the province are met in the same period;

(c) In the case of interest or retributions paid by credits, loans or deposits of funds of any origin or nature obtained abroad:

1. Forty-three percent (43%) when the borrower of the credit, loan or the funds is an entity governed by Law 21.526 or is involved in financing imports of compensable .-excluding cars proveedores granted by the suppliers.

The presumption set out in this section shall also apply if the appellant is any of the other subjects covered by article 49 of this law, a human person or an undivided succession, in such cases provided that the creditor is a bank or financial entity based in jurisdictions not considered to be null or low taxation in accordance with the rules of this law and its regulation or is a matter of jurisdictions that have signed with the Argentine Republic, in addition to agreements of exchange of information The financial entities covered by this paragraph are those under the supervision of the respective central bank or equivalent agency. (Expression is a physical person replaced by a human person. by art. 79 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Identical treatment will be applied when interest or retributions correspond to debt bonds submitted in countries with which there is reciprocity agreement for investment protection, provided that their registration in the Argentine Republic in accordance with the provisions of Law 23.576 and its modifications, is carried out within two (2) years after their issuance.

2. One hundred per cent (100%) when the borrower of the credit, loan or funds is a subject covered by Article 49 of this Law, excluding entities governed by Law 21.526 and its modifications, a human person or an undivided succession and the creditor does not meet the status and requirement set out in the second paragraph of the preceding paragraph. (Expression is a physical person replaced by a human person. by art. 79 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

(Incision replaced by Article 6 of the Act No. 25.784B.O. 22/10/2003. - Watch: From the day of publication in B.O.)

... Forty-three percent (43%) of the interests originated in the following deposits, carried out in the entities governed by law 21.526:

1. Savings box.

2. Special savings accounts.

3. On time.

4. Deposits of third parties or other forms of collection of public funds as determined by the Central Bank of the Argentine Republic pursuant to the provisions of the respective legislation.

(Convention following subparagraph (c) by Act No. 25.063Chapter III, article 4 (z) (b). - Proceeding: From its publication in the Official Gazette and effect will be given to the periods that close after the entry into force of this law or, if any, the current fiscal year to that date. )

(d) SETENTA BY SCIENTO (70 %) of the amounts paid for salaries, fees and other remunerations to persons acting temporarily in the country, such as intellectuals, technicians, professionals, artists not covered by subparagraph (b), athletes and other personal activities, when to perform their duties they do not remain in the country for a period exceeding SEIS (6) months in the fiscal year.

(e) The ACCOUNT FOR SCIENTY (40 %) of the sums paid for the location of movable things made by resident locators abroad.

(f) SESENTA BY SCIENTO (60 %) of the amounts paid for rents or leases of property located in the country.

(g) CINCUENTA BY CIENTO (50 %) of the sums paid for the transfer in onerous title of goods located, placed or used economically in the country, belonging to companies or companies constituted, located or located abroad.

(h) The NOVATE FOR SCIENTI (90 per cent) of the amounts paid for unforeseen gains.

Without prejudice to the provisions of subparagraphs (f) and (g), the beneficiaries of such concepts may, for the determination of the net gain subject to retention, choose between the presumption set forth in such subparagraphs or the amount resulting from deducting from the gross benefit paid or credited, the expenses incurred in the country necessary for its obtaining, maintenance and maintenance, as well as the deductions provided for in this law, according to the type of profit expressly recognized by DIMPOS.

The provisions of this article shall not apply in the case of profits in which this law expressly provides for a different form of determination of the alleged gain.

PART VI

AJUST BY INFLATION

Art. 94 - Without prejudice to the application of the remaining provisions that are not amended by this Title, the subjects referred to in article 49 (a) to (e), for the purpose of determining the net taxable gain, shall deduce or incorporate into the tax result of the liquidated period, the inflation adjustment obtained by the application of the rules of the following articles.

(Article replaced by art. 64 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Art. 95 - For purposes of the inflation adjustment referred to in the previous article, the following procedure should be followed:

(a) The total amount of the asset according to the trade balance or, if any, tax will be detracted from the amounts corresponding to all the concepts indicated in the points below:

1. Real estates and ongoing works on properties, except those that have the character of exchange assets.

2. Investments in materials for the works included in the previous point.

3. Removable furniture – even compensable players – for the purposes of this law.

4. Furniture properties under construction for fixed assets.

5. Intangible property.

6. In forest farms, timber stocks cut or standing.

7. Social shares, shares and shares, including shares of common investment funds.

8. Investments abroad - including financial placements - that do not originate from Argentine sources or that are not affected to activities that generate results from Argentine sources.

9. Non-removable property, except securities and exchange assets.

10. Credits representing signs or advances that freeze prices, carried out prior to the acquisition of the goods covered by points 1 to 9.

11. Contributions and advances made on account of future capital integrations, where there are duly documented or irrevocable contributions of subscription of shares, with the exception of those who compromise interests or updates in conditions similar to those that could be agreed between independent parties, taking into account the normal practices of the market.

12. Outstanding shareholder integration balances.

13. Debtor balances of the holder, owner or partner, which come from outstanding integrations or from operations carried out under conditions other than those that could be agreed between independent parties, taking into account the normal practices of the market.

14. In local foreign capital companies, the debtor balances of a person or group of persons from abroad who participate directly or indirectly in their capital, control or direction, when such balances originate in legal acts that cannot be replenished as held between independent parties, because their benefits and conditions do not conform to normal market practices among independent entities.

15. Costs of incorporation, organization and/or reorganization of the company and development, study or research expenses, to the extent that they were impositively deducted.

16. Advances, retentions and payments to tax and expenditure account, not deductible for the purposes of this tax, which are recorded in the asset.

When assets from points 1 to 7 had been disposed of during the liquidated period, the value they had had at the beginning of the liquidated period would not be part of the amounts to be detracted. The same treatment shall apply if such property had been delivered by any of the concepts referred to in points 1 to 4 of the first paragraph of subparagraph (d).

In cases where exchange assets have been affected as goods of use during the period, the tax value assigned to them at the start of the exercise will be part of the concepts to detract from the asset.

(b) The amount obtained by application of subparagraph (a) shall be deducted from the liability.

I. For these purposes, it shall be understood by liability:

1. Debts (the provisions and forecasts to be disclosed, shall be accepted by this law, which shall be computed for the amounts authorized by it).

2. The benefits received in advance and those that represent benefits for future periods.

3. The amounts of honorariums and gratifications which, pursuant to article 87, have been deducted in the period for which they are paid.

II. For the same purpose, no liability shall be considered:

1. Contributions or advances received in future capital integrations when there are commitments of duly documented or irrevocable contributions of subscription of shares, which in no case devengate interest or updates for the contributor.

2. The credits of the holder, owner or associate, which come from operations of any origin or nature, carried out in conditions other than those that could be agreed between independent parties, taking into account the normal practices of the market.

3. In local foreign capital companies, the credits of a person or group of persons from abroad who participate, directly or indirectly, in their capital, control or address, where such balances originate from legal acts that cannot be reputed as held between independent parties, because their benefits and conditions do not conform to normal market practices among independent entities.

(c) The amount obtained under subparagraphs (a) and (b) shall be updated through the application of the general consumer price index (IPC), provided by the NATIONAL STATISTIC INSTITUTE And CENSOS, taking into account the variation operated in the same between the closing month of the previous year and the closing month of the year that is liquidated. The difference in value obtained as a result of the update shall be considered: (Expression is a higher price index, a general level being replaced by the expression lipid of prices to the consumer general level (IPC), by art. 1 Act No. 27.468 B.O. 4/12/2018. Monitoring: the day of publication in the Official Gazette and will be effective for fiscal years or fiscal years initiated from 1 January 2018, inclusive)

l. Negative adjustment: when the amount of the asset is higher than the amount of the liability, determined according to the general rules of the law and the specials of this title.

2. Positive adjustment: when the amount of the asset is less than the amount of the liability, determined according to the general rules of the law and the specials of this title.

(d) The adjustment resulting from the application of subparagraph (c) shall be added or subtracted, as appropriate, the amounts indicated in the following paragraphs:

I. As a positive adjustment, the amount of the calculated updates applying the consumer price index general level (IPC), provided by the NATIONAL STATISTIC INSTITUTE And CENSOS, taking into account the variation operated between the month of the cash withdrawal, payment, acquisition, incorporation or disabling, as appropriate, until the month of the closing of the period that is liquidated, on the amounts of: (Expression is a higher price index, a general level being replaced by the expression lipid of prices to the consumer general level (IPC), by art. 1 Act No. 27.468 B.O. 4/12/2018. Monitoring: the day of publication in the Official Gazette and will be effective for fiscal years or fiscal years initiated from 1 January 2018, inclusive)

1. Withdrawals of any origin or nature -including those charged to the particular accounts-infected during the period by the owner, owner or partner, or of the funds or assets disposed of in favour of third parties, except in the case of sums that devengate interest or updates or amounts that originate in operations carried out in the same condition as those that could be agreed between independent parties, in accordance with the normal practices of the market.

2. Distributed dividends, except in released shares, during exercise.

3. The actual capital reductions made during the period.

4. The portion of the fees paid in the exercise that exceeds the limits set forth in Article 87.

5. The acquisitions or incorporations made during the liquidation period, of the assets covered in subparagraphs l to l0 of subparagraph (a) affected or not to activities that generate results from Argentine sources, as long as they remain in the assets at the close of the same. Equal treatment will be given when society acquires its own actions.

6. The funds or assets not covered by points 1 to 7, 9 and 10 of subparagraph (a), when converted into investments referred to in item 8 of that subparagraph, or are allocated to them.

II. As a negative adjustment, the amount of updates calculated by application of the consumer price index general level (IPC), provided by the NATIONAL STATISTIC INSTITUTE And CENSOS, taking into account the variation operated between the month of contribution, disposal or affectation, as appropriate, and the month of closing the period that is liquidated, on the amounts of: (Expression is a higher price index, a general level being replaced by the expression lipid of prices to the consumer general level (IPC), by art. 1 Act No. 27.468 B.O. 4/12/2018. Monitoring: the day of publication in the Official Gazette and will be effective for fiscal years or fiscal years initiated from 1 January 2018, inclusive)

1. Contributions of any origin or nature - including those attributable to the particular accounts - and the capital increases made during the liquidation period.

2. Investments abroad, referred to in paragraph 8 (a), where their impact is effected on activities that generate results from Argentine sources, except for property of the nature of those covered by points 1 to 7, 9 and 10 of subparagraph (a).

3. The computable tax cost in cases of disposal of the assets referred to in item 9 (a), or when delivered by any of the concepts referred to in points 1 to 5 of the preceding paragraph.

(e) The amount determined in accordance with the preceding subparagraph shall be the inflation adjustment for the exercise and shall affect as a positive adjustment, increasing the gain or decreasing the loss, or negative, diminishing the gain or increasing the loss, in the result of the exercise concerned.

The procedure provided for in this article will be applicable in the fiscal year in which a percentage of variation in the price index referred to in the second paragraph of Article 89, accumulated in the thirty-six (36) months prior to the end of the period that is liquidated, more than one hundred (100%). (Paragraph incorporated by art. 65 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

The provisions of the preceding paragraph shall apply for periods beginning on 1 January 2018. In respect of the first, second and third year from its validity, this procedure will apply in case the variation of that index, calculated from the beginning and to the closing of each of those exercises, exceeds fifty-five percent (55%), thirty percent (30%) and fifteen percent (15%) for the first, second and third year of application, respectively. (Last paragraph replaced by art. 3° of the Act No. 27.468 B.O. 4/12/2018. Monitoring: the day of publication in the Official Gazette and will be effective for fiscal years or fiscal years initiated from 1 January 2018, inclusive)

Art. 96 - The values and concepts to be computed for the purposes set out in subparagraphs (a) and (b) of the previous article - except for the assets and debts excluded from the assets and liabilities, respectively, which shall be deemed to be the values with which they appear in the trade balance or, where applicable, tax- shall be those determined at the end of the immediate period prior to which the General Regulations of the Title are settled, once adjusted by application of the general rules of the Law and the Law.

The assets and liabilities listed below shall be assessed for all purposes of this law by applying the following rules:

(a) Deposits, credits and debts in foreign currency and stocks thereof: according to the last value of quotation - type of buyer or seller as appropriate - of the ARGENTINA NATION BANK at the end of the year, including the amount of interest that had been accrued to that date.

(b) Deposits, credits and debts in the national currency: for their value at the closing date of each exercise, which shall include the amount of interest and legal updates, agreed upon or set aside, which would have been accrued to that date.

(c) Public Titles, bonds and other values .excluding shares, representative values and certificates of deposit of shares and other values, quotas and social participations, shares of common investment funds and certificates of participation of financial trusts and any other right on trusts and similar contracts. that are co-qualified in exchanges or markets: to the last value of quote at the end of the year. Digital currencies to the value of contributions at the end of the year, as established by the regulation. (Paragraph replaced by art. 66 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Those who are not collated will be assessed for their increased cost, if applicable, with the amount of interest, updates and exchange differences that would have been accrued to the end of the year. The same valuation procedure shall apply to securities issued in foreign currency.

(d) Where the penultimate paragraph of subparagraph (a) of the preceding article is applicable, such assets shall be assessed at the value considered as a computable tax cost at the time of disposal in accordance with the relevant rules of this law.

(e) Debts that represent signs or advances of clients that freeze prices at the date of their receipt: they must include the amount of updates of each of the amounts received calculated by the application of the consumer price index general level (IPC), provided by the NATIONAL INSTITUTE OF STATISTICA And CENSOS, taking into account the variation operated in the same, between the month of entry of the aforementioned concepts and the month of closing of the exercise. (Expression is a higher price index, a general level being replaced by the expression lipid of prices to the consumer general level (IPC), by art. 1 Act No. 27.468 B.O. 4/12/2018. Monitoring: the day of publication in the Official Gazette and will be effective for fiscal years or fiscal years initiated from 1 January 2018, inclusive)

In order to make the tax balance of the initial year, as well as the one to be carried out on 31 December of each year, by those taxpayers who do not carry out a trade balance, the rules established by the IMPOSTIVE GENERAL DIRECTION will be taken into account.

Art. 97 - Those responsible who, as provided for in this Title, must apply the inflation adjustment shall also be subject to the following provisions:

(a) The exemptions set out in article 20 (h), (k) and (v). (Incision replaced by Act No. 25.402Art. 3, subparagraph (d), B.O. 12/1/2001.- Proceedings: Starting from 12/1/2001, the deposits in entities governed by Act No. 21.526 will take effect from 1 January 2001, inclusive.

(b) shall be charged as profits or losses, as appropriate, of the period to be liquidated, the amount of legal updates, agreed or judicially fixed, of credits, debts and securities .excludes shares, representative values and certificates of deposit of shares and other values, quotas and social shares, shares of common funds of investment and certificates of participation of financial trusts and any other entitlements, In the case of Qualified Titles, their respective quotation shall be considered. They shall also charge the amount of the debt updates referred to in subparagraph (e) of the preceding article, in the part corresponding to that period; (Incision replaced by art. 67 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

(c) They shall be charged as profit or, if any, loss, the difference of value resulting from comparing the foreign currency's contribution at the end of the year with the corresponding at the end of the previous year or the date of acquisition, if any, concerning deposits, stocks, credits and debts in foreign currency.

(d) Where assets for which signs or advances have been received are disposed of, under the conditions set out in subparagraph (e) of the preceding article, for the purpose of determining the outcome of the operation, the amount of updates referred to in the aforementioned subparagraph shall be added to the agreed disposition price, calculated until the month of the closure of the immediate period prior to the date of disposal.

(e) In cases where, in accordance with the rules of this law or its regulatory decree, the option of imputing the result of the time-bound sales operations to the fiscal periods in which the respective assessed contributions are required, and it would have been appropriate to compute accrued updates in the period in respect of the unsuccessful balances of assessments at the end, the share of the update may be deferred.

(f) In forest farms not covered by the Law No. 21.695, for the determination of the tax that may correspond to the disposal of the proceeds of its plantations, the computable cost may be updated by the application of the index provided for in Article 89, referring to the date of the respective investment, as indicated in the table prepared by the General IMPOSITIVA DIRECTION for the month to which the date corresponds.

In the case of plantations covered by Decree No. 465 of 8 February 1974, taxpayers may choose to apply the provisions of the preceding paragraph, in which case the amount resulting from the assessment referred to in article 4 of the decree may not be computed as a cost.

Art. 98 - The total or partial exemptions established or established in the future by special laws in respect of Titles, letters, bonds, obligations and other values issued by the national, provincial, municipal or the Autonomous City of Buenos Aires shall have no effect on this tax for human persons and indivisous successions residing in the country or for taxpayers referred to in article 49 of this Act.

(Article replaced by art. 68 of Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

PART VII

OTHER PROVISIONS

Art. 99 - Defeat all provisions contained in national laws -general, special or statutory, except those of the law of the tax on profits-, decrees or any other rule of lower hierarchy, by which the total or partial exemption or deduction is established, of the taxable matter of the tax on profits, of the amount perceived by the taxpayers included in subparagraphs (a), (b) and (c) of article 79,

Art. 100 - Please note that the different concepts that under the name of social benefits and/or fuel vouchers, extension or authorization of the use of purchase and/or credit cards, housing, recreation or rest travel, payment of education expenses of the family group or other similar concepts, are granted by the employer or through third parties in favour of their dependents or employees, are reached by the tax on profits, even if the same does not review the municipal system

Exclude from the provisions of the paragraph prior to the provision of work clothes or any other element linked to the clothing and equipment of the worker for exclusive use in the workplace and to the granting or payment of training or specialization courses to the extent that they are indispensable for the performance and development of the employee ' s or dependent career within the company.

Art. 101 - In the case of private retirement insurance schemes administered by entities subject to the control of the SUPERINTENDANCE OF FOLLOWERS, the amount of the ransom by the beneficiary of the plan shall not be subject to this tax, whatever its cause, to the extent that the amount rescued is applied to the hiring of a new plan with entities operating in the system, within the QUINCE (15) business days following the date of the ransom.

Art. 102 - In the cases of profits or ransoms referred to in article 45 (d) and (e) and article 79 (d) of the same law, the net gravable benefit shall be established by difference between the perceived profits or ransoms and the amounts that had not been deducted for the purposes of the liquidation of this tax, updated, applying the index mentioned in article 89, referred to in the month of December of the tax period

In the case of payment of the benefit or ransom in the form of regular income, a direct relationship shall be established between what is perceived in each fiscal period in respect of the total amount to be received and this proportion shall apply to the total amount of amounts that had not been deducted updated as indicated in the preceding paragraph; the difference between what was perceived in each period and the proportion of contributions that had not been deducted shall be the net gravable benefit of that period.

Art. 103 - This tax shall be governed by the provisions of Act No. 11.683 (t. in 1978 and its amendments), and its application, perception and control shall be carried out by the IMPOSTITIVE GENERAL DIRECTION.

Art. 104 - (Article repealed by Article 6 of the Act No. 27.432 B.O. 29/12/2017. Watch: from the day following the date of publication in the Official Gazette and will result in implementation from 1 January 2018)

Art. 105 - The provisions of this Act, which shall govern until 31 December 1997, shall have the effect that in each case indicates the rules that conform it.

(Note Infoleg: by art. 2nd of the Act No. 27.432 B.O. 29/12/2017 is extended until 31 December 2022, including the validity of this rule. Watch: from the day after its publication in the Official Gazette and will take effect from this date, including.)

(Note Infoleg: by art. 3° of the Act No. 26.545 B.O. 2/12/2009, the validity of this Law is extended until 31 December 2019. Vigilance: from the day of its publication in the Official Gazette, and effect will arise for fiscal exercises that close from 1 January 2010, inclusive. Previous extension: Act No. 26072 B.O. 10/1/2006)

PART VIII

TRANSITORY PROVISIONS

Art. 106 - The tax established by this law replaces the tax on revenues, the tax on the sale of movable values and the tax on eventual profits, in the latter case in the relevant part.

However, the rules of the substituted taxes shall incite the determination of the revenues or profits reached by them when their effects are subject to facts or circumstances that are set after their validity but in accordance with their forecasts.

In addition, the above-mentioned rules will incite the determination of the taxable matter reached by the tribute established by this law, when they extend their effects to future exercises, on the basis of rights or obligations derived from facts or circumstances set up during their validity. In the same vein, the rights to removals or exemptions originating in acts or acts carried out until 31 December 1973 will not be affected, whereas, if any, they will continue their effect until the end of the annual exercise initiated in that year.

For the purpose of the transition process of the levies replaced with the new one, those responsible for such levies shall be subject to all obligations, including substantive obligations, which are necessary to ensure the continuity of the replaced regime, provided that the principle that no imponible matter common to the substitute and substitute tributes is thus reached by more than one of the levies in question.

The EXECUTIVE POWER shall issue the necessary regulatory provisions to regulate the transition referred to in this article, on the basis of the above-mentioned substitute character and the remaining principles indicated for that purpose.

Art. 107 - Where, under regimes aimed at sectoral or regional promotion, sanctioned prior to 25 May 1973, preferential treatments had been granted in relation to the derogation of the charges, the EXECUTIVE POWER shall provide the scope of such treatment with respect to the tax established by this Act, in order to ensure the rights acquired and, through them, the continuity of the previously approved programmes.

Art. 108 - Where the regimes referred to in the previous article had been sanctioned after 25 May 1973, the EXECUTIVE POWER shall regulate the automatic application of such preferential treatments in relation to the tax of this law.

The above treatment shall apply to the regime established by Act No. 19,640.

Art. 109 - Where the compensation provided for in article 20, last paragraph, is appropriate, the offset negative interests and updates shall not be deductible. If such compensation arises a negative balance and proceeds in this regard to the apportionment provided for in article 81, subparagraph (a), the assets originating in the interest and exempted active updates shall be excluded.

Art. 110 - For the purpose of the update provided for in article 25, the amount set out in article 22 shall be deemed effective as at 31 December 1985.

Art. 111 - In cases of disposal of stocks that are collected in stocks or markets - except released shares - acquired prior to the first period beginning on 11 October 1985, it may be decided to consider as acquisition value the value of quotation at the end of the immediate period prior to the precited, and as the date of acquisition the latter.

Art. 112 - Subjects covered in article 49 (a), (b) and (c), for the determination of the inflation adjustment for the first exercise initiated after 11 October 1985, shall be computed at the beginning of the year that the concepts set out in Title VI are liquidated to the assigned or appropriate values assigned at the end of the previous immediate period, in accordance with the valuation standards used for the determination of the inflation adjustment established by Law No. 2194.

The provisions of the preceding paragraph shall not apply to the estate considered as a good of change, whatever its nature, which shall be computed in accordance with the provisions of the third paragraph of paragraph 9 of Article 5 of Law No. 23.260, as amended by article 1 of Law No. 23.525.

Art. 113 - In all cases and without exception, deductible breaches shall be those originated in the oldest period, with no exception from the regime applicable in accordance with the rules in force prior to the reform provided for in Act No. 23,260, those applicable on the basis of this and the emerging articles.

Art. 114 - The breaches accumulated in closed fiscal periods prior to the date of entry into force of this article may not be deducted in the DOS (2) first fiscal exercises that close from the date cited.

Art. 115 - The breach for the first fiscal year that closes from the date of effect of this article shall not be deductible in the following year and the calculation of the time limit of CINCO (5) years provided for in Article 19 shall begin to be counted from the second closed period, even after that in which the loss occurred.

Art. 116 - The breaches mentioned in article 114 that could not be deduced as a result of the suspension provided for by that norm or which differ on the basis of the limitation of the CINCUENTA (50 %) provided for in the previous article, may be deducted, without limitation in time, until its exhaustion. Such deduction shall proceed provided that, if the suspension or limitation in the calculation of the breaches had not existed, they would have been absorbed within the time limits provided for in article 19, as appropriate.

Art. 117 - Subjects whose end-of-year period had been operated until 27 January 1988 shall calculate unpaid advances for the following period, on the basis of net gains encumbered from the previous period without deducting accumulated breaches, if any.

Art. 118 - The provisions of articles 114 and 115 shall not apply to breaches of the dispositions referred to in the last paragraph of article 19.

Art. ... - The second paragraph of Article 69 (b) and the third article added without a number following Article 90 shall be applied to the extent that the gain of the subjects referred to in Article 69 (a) and (b) would have been subject to the liquotas indicated there aplicablesasing the liquotas of seven per cent (7%) and thirty per cent (40 per cent), respectively, from the two fiscal period of the tax period.

In the case of distributed profits that have been generated in fiscal periods for which the taxpayer was reached to the thirty-five per cent liquor (35%), the income of the tax or the retention of dividends or profits, as appropriate.

For the purposes set out in the preceding paragraphs, it shall be considered, without admitting evidence to the contrary, that the dividends or profits made available correspond, first, to the accumulated gains or profits of greater, antiquity.

(Article s/n incorporated after Article 118, replaced by Article 69 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Art. ... - The adjustment for positive or negative inflation, as the case may be, referred to in Title VI of this Act, for the first, second and third period beginning on 1 January 2018 to be calculated on the basis of the verification of the assumptions provided for in the two (2) final paragraphs of Article 95, shall be charged one third (1/3) in that fiscal period and the remaining two thirds (2/3) in equal parts in the next two (2) immediate fiscal periods.

(Second article s/n following article 118, incorporated by art. 4° of the Act No. 27.468 B.O. 4/12/2018. Monitoring: the day of publication in the Official Gazette and will be effective for fiscal years or fiscal years initiated from 1 January 2018, inclusive)

PART IX

GANANCIES OF FOREIGN

IN THE COUNTRY

CHAPTER I

RESIDENCE

(Title IX incorporated by Act No. 25.063, Title III, Article 4°, subparagraph (z) and (b)). Proceedings: From the validity set for relevant purposes by Act No. 24.073. However, the executive branch has observed this validity through Decree No. 1.517/98.)

Residents

Art. 119 - For the purposes of the second paragraph of Article 1 they are considered residents of the country:

(a) Human persons of Argentine, native or naturalized nationality, except those who have lost the status of residents in accordance with article 120. (Expression is a visible existence, replaced by shihumans. by art. 79 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

(b) Human persons of foreign nationality who have obtained their permanent residence in the country or who, without having obtained it, have remained in the country with temporary authorizations granted in accordance with the existing migration provisions, for a period of DOCE (12) months, where temporary absences that conform to the time and conditions established by the regulation will not interrupt the continuity of the stay. (Expression is a visible existence, replaced by shihumans. by art. 79 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Notwithstanding the provisions of the preceding paragraph, persons who have not obtained permanent residence in the country and whose stay in the country is subject to cases that do not involve an intention of habitual stay may prove the reasons that motivated it in the form and conditions established by the regulation.

(c) Indivisible successions in which the offender, on the date of death, was resident in the country in accordance with the provisions of the preceding subparagraphs.

(d) The subjects covered by article 69 (a).

(e) Corporations and companies or single-person enterprises, incorporated or located in the country, including in subparagraph (b) and in the last paragraph of article 49, for the sole purpose of attributing their tax results to the owners or partners who review the status of residents in the country, in accordance with the provisions of the preceding paragraphs.

(f) Trusts governed by Act No. 24,441 and the Common Investment Funds covered by the second paragraph of article 1 of Act No. 24,083 and its amendment, for the purpose of fulfilling the obligations imposed on the trustee and the managing companies, respectively, as administrators of foreign heritage and, in the case of non-financial trusts governed by the first of the above-mentioned laws, for the purposes of taxation,

In the cases covered by subparagraph (b) of the preceding paragraph, the acquisition of the resident status shall have effect from the initiation of the immediate month subsequent to the one in which the permanent residence had been obtained in the country or within which the period established for the establishment of the acquisition of the resident status had been met.

The stable establishments under article 69, paragraph 1 (b), have the status of residents for the purposes of this law and are subject to the rules of this Title for their foreign source gains.

(Article replaced by Act No. 25,239, Title I, art.1°, subparagraph (p). - Watch: From 31/12/99, the exercises starting from that date will take effect. )

Loss of resident status

Art. 120 - Human persons who review the status of residents in the country shall lose it when they acquire the status of permanent residents in a foreign State, in accordance with the provisions governing migration or where, having not been acquired previously, they shall remain on an ongoing basis abroad for a period of twelve (12) months, in which the temporary presences in the country that are in conformity with the terms and conditions that are not regulated. (Expression is a visible existence, replaced by shihumans. by art. 79 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

In the case of continued stay abroad referred to in the preceding paragraph, persons who are absent from the country for reasons that do not involve the intention of staying abroad on a regular basis may credit such circumstances in the time, form and conditions established by the regulation.

The loss of resident status will result from the first day of the immediate month following the one on which permanent residence had been acquired in a foreign State or the period determining the loss of resident status in the country, as appropriate.

Art. 121 - Notwithstanding the provisions of the preceding article, they shall not lose the status of residents for the continued stay abroad, human persons residing in the country acting abroad as official representatives of the national State or in compliance with functions entrusted by it or by the provinces, municipalities or the Autonomous City of Buenos Aires. (Expression is a visible existence, replaced by shihumans. by art. 79 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Art. 122 - When the loss of the resident status occurs prior to the absence of persons from the country, the latter shall be credited to the Federal Public Income Administration, autarchical entity within the scope of the Ministry of Economy and Public Works and Services, the acquisition of the resident status in a foreign country and the fulfilment of the obligations relating to the gains of Argentine and foreign sources obtained in the fraction of the period of the tax period from the beginning,

On the other hand, if the loss of the resident status occurred after the persons are absent from the country, the accreditation concerning this loss and the causes that determined it, as well as the one concerning the fulfilment of the obligations referred to in the previous paragraph, considering in this case the fraction of the fiscal period that occurred from the beginning until the end of the month following to the one in which the public administration was reported, shall be made to the country

The fulfilment of the obligations set out in the preceding paragraphs shall not release the persons covered by them from their responsibility for the differences in taxes that may be determined by periods prior to that in which the loss of the resident status or the fraction of the fiscal year occurred until such time as the effect is concerned.

Art. 123 - Human persons who have lost the status of a resident shall, from the day on which the loss is effected, be the beneficiaries of the outsider in respect of the gains of Argentine source that they obtain from that day onwards, subject to the provisions of Title V, for which purpose they shall communicate that change of residence or, where appropriate, the loss of the resident status in the country, to the relevant retention agents. (Expression is a visible existence, replaced by shihumans. by art. 79 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Retentions that may have been omitted prior to the communication of the change of residence shall be practiced when future payments are made and, if not possible, such a circumstance shall be communicated to the Federal Public Income Administration, an autonomous entity within the Ministry of Economy and Public Works and Services.

Art. 124 - The Federal Public Income Administration, an autonomous entity within the Ministry of Economy and Public Works and Services, shall determine the form, time and conditions under which the accreditations provided for in article 122 shall be made and, where appropriate, the communications referred to in its second paragraph.

In addition, with regard to the provisions of article 123, it shall determine the manner, time and conditions in which the communication of change of residence must be made to the retention officers and, where appropriate, that concerning the impossibility of holdings omitted on the occasion of future payments.

Double residence

Art. 125 In cases where human persons, who have obtained permanent residence in a foreign State or who have lost the status of residents in the Argentine Republic, are considered to be residents of another country for tax purposes, continue to reside in or return to the national territory in order to remain in it, such persons shall be deemed to be resident in the country: (Expression is a visible existence, replaced by shihumans. by art. 79 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

(a) When they maintain their permanent housing in the Argentine Republic;

(b) In the event that they maintain permanent housing in the country and in the State that granted them permanent residence or that considers them resident for tax purposes, if their centre of vital interests is located in the national territory;

(c) Failure to determine the location of the centre of vital interests, if they habitually live in the Argentine Republic, a condition that will be considered fulfilled if they remain in it for longer than in the foreign State that granted them permanent residence or that considers them resident for tax purposes, during the period for which the regulation is established;

(d) If, during the period referred to in subparagraph (c), they remain in the same time in the country and in the foreign State that granted them residence or considers them resident for tax purposes, where they are of Argentine nationality.

When, by application of the provisions of the preceding paragraph, a human person should be considered a resident in the country, the treatment set out in the second paragraph of article 1 shall be waived from the time when the loss of that condition was effected or, where appropriate, from the first day of the month following his return to the country. (Expression is a visible existence, replaced by shihumans. by art. 79 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

If the person to whom the treatment indicated above had been granted had been subject from the initial date covered by the same, of the retentions provided for in Title V, such retentions may be computed as payment in the proportion that does not exceed the tax attributable to the proceeds of Argentine source that originated them, determined according to the regime applicable to the residents of the country. The portion of the retentions that are not computable may not be charged with the tax originated by other profits or may be transferred to subsequent periods or be subject to compensation with other charges, transfer to third parties or return.

When the persons to whom the status of residents of the country is attributed in accordance with the provisions of this article, maintain their status as residents of a foreign State and undertake changes in their situation that indicate that they have transferred their residence to that State in a definitive manner, they must establish that circumstance and its consequence to the Federal Public Income Administration, autarchic entity within the Ministry of Economy and Public Works and Services.

Non-residents present in the country on a permanent basis

Art. 126 - They are not resident in the country:

(a) Members of diplomatic and consular missions of foreign countries in the ARGENTINA REPUBLIC and their technical and administrative personnel of foreign nationality who, at the time of their recruitment, did not have the status of residents in the country in accordance with article 119 (b), as well as family members who did not have that status with them.

(b) Representatives and agents acting in international agencies to which the Nation is a party and carry out its activities in the country, where they are of foreign nationality and should not be considered to be resident in the country as set out in article 119 (b) when undertaking such activities, as well as family members who do not review the status of residents in the country accompanying them.

(c) Human persons of foreign nationality whose presence in the country is determined for reasons of a properly accredited working nature, which require their stay in the ARGENTINA REPUBLIC for a period not exceeding CINCO (5) years, as well as family members who do not review the status of residents in the country who accompany them. (Expression is a visible existence, replaced by shihumans. by art. 79 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

(d) Human persons of foreign nationality, who enter the country with temporary authorizations granted in accordance with the current migration standards, with the aim of completing secondary, tertiary, university or postgraduate studies in the country, in official or officially recognized establishments, or conducting research work by receiving as the sole retribution of scholarships or similar assignments, while maintaining the temporary authorization granted for such purposes. (Expression is a visible existence, replaced by shihumans. by art. 79 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Notwithstanding the provisions of this article, in respect of their gains from Argentine sources, the subjects covered by the preceding paragraph shall be governed by the provisions of this law and its regulations applicable to the residents of the country.

(Article replaced by Act No. 25,239, Title I, art.1°, subparagraph (q). - Watch: From 31/12/99, the exercises starting from that date will take effect. )

Chapter II

General provisions

Source

Art. 127 - The profits of a foreign source are those covered by article 2, which are derived from goods located, placed or used economically abroad, from the conduct abroad of any act or activity that may produce a benefit or of events occurring outside the national territory, except those expressly defined as an Argentine source and those originated by the sale abroad of goods exported definitively from the country to be disposed of abroad, which constitute profits.

Art. 128 - The profits attributable to permanent establishments located outside the country ' s resident holders constitute, for the latter, foreign source gains, except where they, according to the provisions of this law, should be considered as an Argentine source, in which case the permanent establishments that obtain them will continue to review the status of beneficiaries of the outside and subject to the treatment that this legal text establishes for them.

The establishments included in the preceding paragraph are those organized in the form of a stable company for the development of commercial, industrial, agricultural, extractive or of any kind, which originate for their holders residing in the Argentine Republic profits of the third category, according to the definition established in the article without number incorporated in the following article 16, it is understood that in the cases in which that article refers to the foreign language referred to in the country, the foreign language

The previous definition also includes lotteries for the purpose of urbanization and the construction and disposal of properties under regimes similar to that of horizontal ownership of the Civil and Commercial Code of the Nation, carried out in foreign countries.

(Article replaced by art. 70 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Art. 129 - In order to determine the tax result of the foreign source of the permanent establishments referred to in the previous article, accounting records should be carried out separately from those of their resident holders in the country and those of other stable establishments outside the same holders, making the necessary adjustments to establish such a result. (Expression stable stability is replaced by permanent enlightenment, by art. 79 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

For the purposes set out in the preceding paragraph, transactions made between the owner of the country and his permanent establishment abroad, or by the latter with other permanent establishments of the same holder, installed in third countries, or with persons or other related entities, domiciled, constituted or located in the country or abroad, shall be deemed to have been carried out between independent parties, with the understanding that those transactions give rise to counterclaims that must conform to the same, (Expression stable stability is replaced by permanent enlightenment, by art. 79 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Where the contractions do not conform to those that have agreed on independent parties, the excess and default differences that are recorded in respect of those that have agreed to such parties, respectively, in the responsibility of the resident holder or in the charge of the permanent establishment with which the transaction was made, shall be included in the Argentine source proceeds of the resident holder. In the event that the differences indicated are recorded in transactions carried out between establishments of the same holder installed in different foreign countries, the benefits they bear will be included in the foreign source gains of the permanent establishment that would have ceased to obtain them following the fixed counter-budgeting. The criterion should be applied in respect of transactions that are carried out with other persons or other related entities by the establishments. (Expression stable stability is replaced by permanent enlightenment, by art. 79 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

If the separate accounting does not adequately reflect the tax result of a permanent establishment of a foreign source, the FEDERAL ADMINISTRATION OF PUBLIC INCOME, an auto-archic entity within the scope of the MINISTERY OF ECONOMY AND ARTWORKS AND PUBLIC SERVICES, may be determined on the basis of the remaining accounting records of the resident holder in the country or on the basis of other appropriate indices. (Expression stable stability is replaced by permanent enlightenment, by art. 79 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

(Article replaced by Act No. 25,239, Title I, art.1°, subparagraph (r). - Watch: From 31/12/99, the exercises starting from that date will take effect. )

Art. 130 - Transactions made by residents in the country or by their stable establishments installed abroad, with persons or other entities domiciled, constituted or located abroad with which the former are linked, shall be considered for all purposes as held between independent parties, when their counterclaims and conditions conform to normal market practices between independent entities.

In the absence of compliance with the pre-established requirement for transactions to be considered to be held between independent parties, the excess and default differences that, respectively, are recorded in the counterfeitings by the controlling persons and those of their stable establishments installed abroad, or in the hands of the controlled society, in respect of which they have corresponded according to the normal market practices between independent entities, the established foreign source shall be included, as appropriate, For the purposes of price determination, the rules provided for in Article 15 shall apply, as well as those relating to transactions with countries of low or no taxation established therein.

For the purposes of this article, they constitute controlled societies incorporated abroad, those in which human or ideal persons resident in the country or, where appropriate, indivisous successions that review the same condition, are the owners, directly or indirectly, of more than the CINCUENTA BY CIENTO (50%) of their capital or count, directly or indirectly, with the number of votes necessary to prevail in the assemblies. For this purpose, consideration shall also be given to the provisions of the article incorporated after article 15. (Expression is a visible existence, replaced by shihumans. by art. 79 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

(Article replaced by Act No. 25,239, Title I, art.1°, subparagraph (s). - Watch: From 31/12/99, the exercises starting from that date will take effect. )

Net gain and net gain subject to tax

Art. 131 - The determination of the net gain of foreign source shall be made in accordance with the provisions of article 17 and the remaining provisions contained in headings II and III, while their scope allows them to relate to the proceeds of that source, with the modifications and adjustments provided for in this title. The regulation shall establish the legal provisions that are not applicable to determine the aforementioned net gain.

In order to determine the net gain subject to foreign source tax, natural persons and indivisous successions residing in the country shall detract from the net gain defined in the preceding paragraph, the deductions covered in article 23 (a) and (b), to the extent that they exceed the net gain of Argentine source for the same fiscal year.

Art. 132 - The tax result of a foreign source of stable establishments defined in Article 128 shall be determined in the currency of the country in which they are installed, applying, where appropriate, the conversion rules that for them are established in this title. Its incumbents resident in the country will convert these results to Argentine currency, considering the exchange rate provided for in the first paragraph of Article 158 for the closing day of the annual period of the establishment, computing the type of exchange buyer or seller, according to which the tax result expressed a profit or a loss, respectively.

In the case of foreign proceeds not attributable to such establishments, the net profit shall be determined in Argentine currency. To that end, except in the cases specifically provided for in this title, the profits and deductions will be considered the dates and exchange rates determined by the regulation, in accordance with the conversion rules for foreign source gains falling into the third category or with the imputation applicable.

Competitiveness and expenditure

Art. 133 The imputation of profits and expenses covered by this Title shall be carried out in accordance with the provisions of Article 18 applicable to them, with the following adjustments:

(a) To determine the results attributable to the permanent establishments defined in article 128, they shall be charged in accordance with article 18, as provided for in the fourth paragraph of subparagraph (a) of its second paragraph and its fourth paragraph.

(b) The tax results of the permanent establishments referred to in the preceding paragraph shall be charged by their holders residing in the country .completed in article 119, (d) and (e), to the year in which the corresponding annual exercise of the first or, when their holders are human persons or indivisive successions resident in the country, to the fiscal year in which the act occurs.

(c) The gains made directly by the residents of the country included in article 119 (d), (e) and (f), not attributable to the stable establishments referred to above, shall be charged to the fiscal year in the manner provided for in article 18, as appropriate, in the first three paragraphs of subparagraph (a) of its second paragraph, considering the profits of the annual period to be attributable to it in the fourth paragraph.

Notwithstanding the above provisions, the proceeds paid abroad by retention in the source on a one-time and final payment basis at the time of accreditation or payment may be charged on that occasion, provided that they do not come from operations carried out by the country ' s permanent establishments under subparagraph (a) above with such establishments or are subject to benefits paid or credited by the latter to the former. When this option is adopted, it shall apply to all proceeds subject to the payment modality that authorizes it and must be kept at least for a period of five (5) annual periods.

(d) The gains obtained by trust, trustees, foundations of private interest and other similar structures constituted, domiciled or located abroad, as well as any contract or arrangement held abroad or under a foreign legal regime, the main purpose of which is the administration of assets, shall be charged by the resident subject that controls them to the exercise or fiscal year in which the annual exercise of such entities, contracts or arrangements is completed.

It will be understood that a subject possesses control when there is evidence that the financial assets are kept in his or her power and/or are administered by that subject (including among others the following cases: (i) when it comes to trusts, trusts or foundations, revocable, (ii) when the constituent subject is also beneficiary, and (iii) when that subject has decision-making power, directly or indirectly to invest or disinvert assets, etc.

(e) The profits of the residents of the country obtained by their participation in companies or other entities of any type constituted, domiciled or located abroad or under a foreign legal regime, shall be charged by their shareholders, partners, shareholders, holders, control or beneficiaries, resident in the country, to the exercise or fiscal year in which the annual period of such companies or entities, in the proportion of their participation, are not included)

The provisions of the preceding paragraph will be applicable as long as the aforementioned companies or entities do not possess fiscal personality in the jurisdiction in which they are constituted, domiciled or located, the rents obtained from their shareholders, partners, shareholders, holders, controllers or beneficiaries must be directly attributed.

(f) The profits of the residents of the country obtained by their direct or indirect participation in societies or other entities of any type constituted, domiciled or located abroad or under a foreign legal regime, shall be charged by their shareholders, partners, shareholders, holders, controllers or beneficiaries residing in the country to the exercise or fiscal year in which the corresponding annual exercise of the first ones is completed, as long as the requirements are concurrently met

1. That the rents in question do not receive specific treatment in accordance with the provisions of the preceding subparagraphs (a) to (e).

2. That the residents of the country . themselves or together with (i) entities on which they possess control or bond, (ii) with the spouse, (iii) with the convivant or (iv) with other taxpayers united by bonds of kinship, in ascending line, descending or collateral, for consanguinity or affinity, up to the third degree inclusive (5 have a participation equal or greater than fifty percent, (50%) in the assets.

This requirement shall be deemed to have been met, regardless of the percentage of participation, when the resident subjects in the country, in respect of the foreign entities, meet any of the following requirements:

(i) They pose under any. Title the right to dispose of the assets of the entity.

(ii) They have the right to the choice of most directors or administrators and/or to integrate the directory or board of directors and their votes are those that define the decisions taken.

(iii) They have the power to remove most directors or administrators.

(iv) They have a current right on the benefits of the entity.

This requirement will also be considered to be met, regardless of the percentage of participation of residents in the country, when at any time of the annual period the total value of the assets of foreign entities comes at least thirty per cent (30%) of the value of financial investments generating passive income from Argentine sources deemed exempt to foreign beneficiaries, in the terms of Article 20(w).

In all cases, the result will be attributed according to the percentage of participation in heritage, results or rights.

3. Where the outside entity does not have the organization of material and personal means necessary to carry out its activity, or when its income originates from:

(i) Passive income, when they represent at least fifty percent (50%) of the income of the year or fiscal year.

(ii) Income of any kind that generates fiscally deductible expenses directly or indirectly for linked persons residing in the country.

In the cases referred to in the preceding paragraph, the results of such rents shall be charged in accordance with the provisions of this paragraph only.

4. That the amount actually entered by the non-resident entity, in the country in which it is constituted, domiciled or located, attributable to any of the incomes covered by the preceding paragraph 3, corresponding to taxes of identical or similar nature to this tax, is less than seventy-five percent (75%) of the corporate tax that would have corresponded according to the rules of the tax law. It is presumed, without admitting evidence to the contrary, that this condition operates, if the outside entity is constituted, domiciled or based in non-cooperative or low- or no-tax jurisdictions.

Identical treatment should be noted with respect to indirect participations in non-resident entities that meet the conditions mentioned in the preceding paragraph.

The provisions of this section shall not apply when the local subject is a financial entity governed by law 21.526, an insurance company covered by law 20.091 and also in cases of common investment funds governed by law 24.083.

(g) The fees obtained by residents of the country as directors, trustees or members of the monitoring councils or similar executive bodies of offshore companies shall be charged to the fiscal year in which they are perceived.

(h) The benefits arising from compliance with the requirements of private retirement insurance schemes administered by outside entities or by permanent establishments installed abroad by entities, resident in the country under the control of the Superintendency of National Insurance, as well as the withdrawal bailouts to the insured of such schemes, shall be charged to the fiscal year in which they are perceived.

(i) The imputation provided for in the last paragraph of article 18 shall apply to the erogations made by holders residing in the country covered by article 119 (d) and (e) of the permanent establishments referred to in subparagraph (a) of this article, when such erogations establish gains from Argentine source attributable to the latter, as well as to those that make residents in the country and render the same foreign control.

The charge of the incomes referred to in subparagraphs (d), (e) and (f) above shall be the one that would have been applied by the resident subject in the country, in accordance with the category of income in question, computing the operations carried out in the exercise in accordance with the rules relating to the determination of net income, conversion and liquotas, which would have been applicable to them in direct form. The regulation shall establish the treatment to grant dividends or profits originating in profits that have been charged on the basis of such forecasts in fiscal years or years preceding the distribution of such dividends and utilities.

(Article replaced by art. 71 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Compensation for breakthroughs with profits

Art. 134 - In order to establish the net gain of foreign sources, the results obtained within each and between the different categories shall be compensated, considering for this purpose the results from all sources located abroad and those from the permanent establishments specified in Article 128.

When the above-mentioned compensation resulted in a loss, the latter, updated in the form set out in the eleventh paragraph of article 19, may be deducted from the net profits of foreign source obtained in the next five (5) years, computed in accordance with the Civil and Commercial Code of the Nation. After the last of those years, the remaining breach cannot be compensated.

If a net gain arises from the aforementioned compensation or after the deduction, provided for in the preceding paragraphs, the losses of Argentinean source shall be charged against it . in its case, duly updated que which are deductible in accordance with the ninth paragraph of that article 19, whose charge for the net gain of Argentine source of the same fiscal year would not have been possible.

(Article replaced by art. 72 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Art. 135 - Notwithstanding the provisions of the previous article, the breaches derived from the disposal of shares, representative values and certificates of deposit of shares and other values, quotas and social participations .including common funds of investment or entities with another denomination that fulfil equal functions and trusts or similar contracts digitales, digital coins, Titles, bonds and other values, regardless of the subject that experiences them, will be considered net exercises of specific nature and only profits in the next five (5) years, computed according to the Civil and Commercial Code of the Nation.

Except for those experienced by permanent establishments, for the purpose of deduction, the breaches shall be updated in accordance with the provisions of the eleventh paragraph of article 19.

Argentinian sources ' breaches originating from investments .including digital currencies y and operations referred to in Chapter II of Title IV of this Act may not be charged against net profits from foreign sources from the disposal of the same type of investment and operations or be subject to deduction provided for in the third paragraph of Article 134.

(Article replaced by art. 73 de la Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Art. 136 - For the purposes of the compensation provided for in the preceding articles, the amounts authorized to deduct the second paragraph of article 131 shall not be considered losses.

Exemptions

Art. 137 - Exemptions granted by article 20 that, according to the scope of each case may be applicable to foreign source gains, shall with respect to them the following exclusions and adequacies:

(a) The waiver provided for in subparagraph (h) shall not apply when the deposits it envisages are made in or by stable establishments located outside of the institutions resident in the country referred to in that paragraph. (Incision replaced by Act No. 25,239, Title I, art.1°, subparagraph (v). - Watch: From 31/12/99, the exercises starting from that date will take effect. )

(b) The exclusions set forth in subparagraphs (i), last paragraph and (n), the benefits and rescues, net of contributions, derived from private retirement insurance schemes administered by entities constituted abroad or by stable establishments installed abroad by institutions resident in the country subject to the control of the Superintendence of Insurance of the Nation, under the Undersecretariat of Banks and Insurance of the Ministry of Public Economy

(c) The exclusion set out in the last paragraph in fine of subparagraph (v) with respect to updates that constitute foreign source gains does not cover the exchange differences to which this Title attributes the same source. (Incision replaced by art. 73 of the Act No. 27.260 B.O. 22/7/2016. Watch: from the day after your publication in the Official Gazette.)

Undocumented departures

Art. 138 - When the situation provided for in article 37 is set with respect to erogations that are linked to the acquisition of foreign proceeds, the treatment provided for in that rule shall be applied, except when the existence of sufficient evidence is demonstrated to presume that they were intended for the acquisition of goods or did not produce taxable gains in the hands of the beneficiary.

In cases where the demonstration results in the presumptions set out in the preceding paragraph, the entry referred to in the same article shall not be required, without the deduction of the erogations, except in the case of the acquisition of property, in which case they shall receive the treatment provided by this title according to the nature of the goods to which they were assigned.

Chapter III

First category wins

Art. 139:- They are included in article 41 (f), property located outside the country ' s resident owners for permanent housing, keeping them enabled to provide them with accommodation at all times and on a continuous basis.

For the purposes of the application of subparagraphs (f) and (g) of the article referred to in the preceding paragraph, with respect to property located outside the national territory, it is presumed, without admitting evidence to the contrary, that the location value or presumptive lease attributable to the same, is not less than the rent or lease that the owner would obtain if he rents or leases the property or the portion of the property that he or she occupies free or at a specified price.

Chapter IV

Second category gains

Art. 140 - They constitute gains from a foreign source included in article 45, those set forth in the same source as sources located abroad - excluding that covered by subparagraph (i) - with the aggregates described below:

(a) The dividends or profits distributed by companies or other entities of any type constituted, domiciled or located abroad, while such rents are not covered by the following subparagraphs.

For this purpose, the provisions of the following article shall apply, as well as the assumptions set out in the first article incorporated after article 46. (Substituted decision by art. 74 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

(b) Foreign earnings obtained as a beneficiary of a trust or equivalent legal figures.

For the purposes of this subparagraph, all distributions made by the trust or equivalent figure shall be deemed to be profitable, except as evidence to the contrary that the trust did not benefit and do not possess accumulated profits generated in periods prior to the last performance, including in both cases capital gains and other enrichments. If the taxpayer proves in the manner indicated that the distribution exceeds the above-mentioned benefits, only the proportion of the distribution corresponding to the latter shall be considered gain;

(c) The net benefits of contributions, derived from the implementation of private retirement insurance schemes administered by constituted entities abroad or by stable establishments installed abroad by resident entities in the country subject to the control of the Superintendence of National Insurance, under the Undersecretary of Banks and Insurance of the Ministry of Economy and Public Works and Services Economic Policy Secretariat;

(d) Net repurchase of contributions, originated in the breakdown of private retirement insurance schemes indicated in the preceding subparagraph;

(e) The profits distributed by the common investment funds or equivalent figures that fulfil the same function constituted abroad;

(f) The profits generated by the location of goods exported from the country are considered to be included in subparagraph (b) as a result of a lease with a purchase option entered into with a foreign owner.

Art. 141 - The dividends in money or in kind - including released shares - distributed by the societies referred to in subparagraph (a) of the previous article, are entirely subject to the tax irrespective of the business funds with which the payment is made. The dividends are not considered to be subject to the tax in stocks from revalue or accounting adjustments, not originated in liquid and realized profits.

For the purposes set out in the preceding paragraph, the actions released shall be computed by their nominal value and the remaining dividends in kind by their ordinary value in the square where the goods are located at the time of the making available to the dividends.

Art. 142 - In the case of total or partial rescue of shares, the distribution dividend will be considered to be the difference between the ransom amount and the computable cost of the shares. In the case of released actions distributed prior to the validity of this title or those whose distribution is not subject to the tax in accordance with the provisions of the final part of the first paragraph of the preceding article, it shall be considered that its computable cost is equal to zero (0) and that the total amount of the ransom constitutes a dividend subject to imposition.

The computable cost of each action will be considered as a numerator the amount attributed to the net assets item in the trade balance of the last year closed by the issuing entity, immediately prior to the rescue, deduced the liquid and realized profits that integrate it and the reserves that originate in utilities that meet the same condition, and as denominator the actions in circulation.

For the purposes set forth in the preceding paragraphs, the amount of the ransom and the computable cost of the stocks shall be converted to the appropriate currency as provided for in Article 132, considering respectively the date on which the ransom was made and the closing of the exercise taken as the basis for the determination of the computable cost, except when the ransom or the computable cost, or both, are expressed in the same currency as that article for the purposes of the conversion.

Where the actions that are rescued belong to residents of the country covered by article 119 (d), (e) and (f) or to stable establishments defined in article 128 and that they have acquired them to other shareholders, it shall be understood that the ransom involves an alienation of such actions. In order to determine the outcome of such an operation, the corresponding computable cost in accordance with the provisions of the second paragraph shall be considered as a selling price and as a cost of acquisition obtained through the application of article 152 and, if applicable, of article 154. If the result is a loss, it may be compensated with the amount of the dividend from the ransom that originates it and in the case of an unrepaired loss remnant, the treatments provided for in article 135 will apply to it.

Art. 143 - With regard to the benefits and ransoms provided for in article 140 (c) and (d), the gain shall be established in the manner provided for in article 102, without applying the updates provided by the same.

For the purposes of this article, contributions made in foreign currency will be converted to Argentine currency at the date of payment.

When the countries of incorporation of the entities that manage the private retirement insurance schemes or in which stable establishments of entities subject to the control of the Superintendence of Insurance of the Nation are installed, under the Undersecretary of Banks and Insurance of the Economic Policy Secretariat of the Ministry of Economics and Works and Public Services, which make such changes coefficient, admit the updating of the contributions made to the purposes of the determination, The difference in value that is obtained as a result of that update, converted to Argentine currency at the last date indicated, will be deducted from the profit set out in the form set out in the first paragraph of this article.

The treatment established above shall proceed provided that the treatment applied in the countries considered in the previous paragraph on the basis of its application, as well as the indices or coefficients contemplated for that purpose.

Art. 144 - When capitals are applied in foreign currency located abroad to obtain vital incomes, they will be converted to Argentine currency at the date of payment of them.

Art. 145 - For the purposes provided for in article 48, where it is to be understood that the credits arising from the debts to which the debt relates constitute the placement or economic use of capital in a foreign country, the type of interest to be considered may not be less than the largest fixed by the banking institutions of that country for operations of the same type, to which, if any, the agreed updates or adjustments should be added..

Art. ... - . For purposes of the determination of the proceeds for the disposal of goods covered by this category, the costs or investments made in a timely manner as well as the updates applicable under the provisions of the respective jurisdiction, expressed in the currency of the country in which the goods were found to be located, placed or used in a financial manner, shall be converted to the type of trader exchange considered by article 158, corresponding to the date on which the goods are produced.

(Article s/n incorporated after Article 145, by Article 75 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Chapter V

Third category gains

Income covered

Art. 146 - The foreign source gains obtained by those responsible under article 49, subparagraphs (a) to (d), and the last paragraph of the same article and those responsible for the subjects covered by article 119 (f), include, where appropriate:

(a) Attributes to stable establishments defined in article 128.

(b) Those that are attributable to them as shareholders, partners, shareholders, holders, controllers or beneficiaries of companies and other entities constituted abroad ., including common funds of investment or entities with another denomination that perform equal functions and trusts or similar contracts sin, without being applicable in relation to dividends and profits, as set out in article 64.

(c) Those originated by the exercise of the, option of purchase in the case of goods exported from the country as a result of locating contracts with option of purchase held with foreign owners.

In the case of humans and indivisous successions residing in the country, they also constitute foreign source gains of the third category: (i) those attributable to permanent establishments defined in article 128 and (ii) those which are charged under the provisions of article 133 (d), (e) and (f), as long as they do not correspond to other categories of profits. The regulation shall establish the procedure for determining such rents, taking into account the provisions of the laws of the analogous taxes that govern in the countries of constitution or location of the said entities or the accounting standards applicable therein.

Where appropriate the computation of the compensations provided for in the second paragraph of Article 49 as a result of activities carried out abroad, the third category shall be deemed to be gains in the entire category, without prejudice to the deduction of the necessary expenses reimbursed through it or incurred to obtain them, provided they are supported by the documentation.

(Article replaced by art. 76 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Art. 147 - In order to determine the tax result of the stable establishments defined in Article 128, the proceeds of Argentine source attributable to them, as well as the costs, expenses and other deductions related to their obtaining, should be excluded.

For the purposes of such exclusions, net gain shall be considered, the net gain presumed by article 93 - or those provisions referred to in its last paragraph - and as costs, expenses and deductions, the proportion of income not included in the same, which shall apply even if the gains of Argentine source are exempt profits.

Attribution of results

Art. 148 - The country-based incumbents of stable establishments defined in Article 128 shall be assigned the tax results of foreign sources, even if the benefits had not been paid or credited to them in their accounts. Identical criteria will apply the shareholders resident in the country of companies for actions incorporated or located abroad.

The allocation set out in the preceding paragraph shall not be in respect of foreign source breaches attributable to such establishments and originated by the disposal of shares, quotas or social participations .including quotas part of the common funds of investment or institutions that fulfil the same function los those expressed in the currency of the country in which they are installed shall be compensated in the manner provided for in article 135.

(Article replaced by Act No. 25,239, Title I, art.1°, subparagraph w). - Watch: From 31/12/99, the exercises starting from that date will take effect. )

Art. 149 - (Article repealed by art. 80 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Art. 150 - The tax result of the foreign source of the subjects covered in subparagraphs (b) to (d) and last paragraph of article 49 shall be treated in the manner provided for in article 50, not applying the provisions of its last paragraph.

The above treatment shall not apply with respect to foreign source breaches arising from the disposal of shares, representative values and certificates of deposit of shares and other values, quotas and social participations .including shares of common funds of investment or entities with another denomination that fulfil equal functions and certificates of participation of financial trusts and any other right on trusts and similar contracts.

(Article replaced by art. 77 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Art. 151 - The existence of exchange assets, except immovable ones, of stable establishments defined in article 128 and of those acquired or developed outside the national territory by residents of the country, for sale abroad, shall be computed, according to the nature of the same, using the methods established in article 52, without considering, where appropriate, the updates provided for in respect of them and applying: the remaining provisions of that article with the adequacies and aggregates:

(a) The value of the farm of the breeding establishments shall be determined by the method set out in subparagraph (d) of article 52;

(b) The value of the stocks of forest farms will be established by considering the cost of production. When the countries in which the permanent establishments of the exploitation are installed, in their taxes similar to the tax of this law, they admit the updates of that cost or apply adjustments of a global or integral nature to contemplate the effects of inflation on the tax result, the corresponding cost will be updated taking into account the different investments that make it, from the date of the realization of the same to the date of the period of the period, depending on the variations that are experienced. The update considered in this paragraph shall proceed provided that the treatments adopted in the countries of installation of the establishments and the indices or coefficients used by them for the purpose of their application are credited;

(c) The value of stockpiles of mines, quarries and similar goods shall be assessed in accordance with article 52 (b).

In the case of buildings and construction works that review the nature of exchange goods, the value of stocks will be determined by applying the rules of Article 55, without computing the updates it contemplates.

Art. 152 - Where assets are disposed of as part of the fixed asset of stable establishments defined in article 128, or acquired, developed or constructed abroad by residents in the country, to affect the production of foreign source earnings, the computable cost, in accordance with the nature of the alienated goods, shall be determined in accordance with the provisions of articles 58, 59, 60, 61, 63 and 65, without regard for the same updates. In cases where they authorize the decrease in the cost in the amount of amortizations, the same will be determined according to the provisions of this title. When actions are disposed of from revalues or accounting adjustments or received as a dividend before the validity of this title and issued by the society that made the distribution, no cost will be computed.

In the case of public securities, bonds or other securities issued by foreign States, their political subdivisions or official or joint entities of such States and subdivisions, as well as by foreign companies or entities, the tax cost considered by article 63 will be the cost of acquisition.

Art. 153 - Where furniture is disposed of abroad by residents in the country, under the export-for-consumption regime, in order to apply them to the production of foreign source income, the computable cost shall be due to the tax value attributable to the resident in the country at the beginning of the period in which the transfer was made or, if the acquisition or completion of the manufacture, manufacture or construction would have taken place after the start of the period

The same criterion shall apply when goods are disposed of which are economically used or placed in the country, were used or placed economically abroad for the same purpose, with the exceptions imposed by the nature of the goods disposed of.

Art. 154 - Where the countries in which the goods referred to in articles 152 and 153 are located, the nature of which corresponds to that of articles 58, 59, 60, 61 and 63, or those in which the stable establishments defined in article 128 of which the assets are part of such assets are set up, they may in their laws relating to the taxes similar to that of this law, the updating of their costs in order to determine the profit of the same

The same treatment shall apply when the countries concerned apply any of the measures indicated in respect of the amounts invested in the development, construction or manufacture of movable property amortizable or in buildings or improvements made on real estate, in which case the update shall be made from the date on which the investments were made to the date of determination of the cost of the first listed property and of the constructions or improvements made on real estate or, in the latter case, to the date on which they are treated

If the countries referred to in the first paragraph do not establish in their laws taxes similar to that of this law, but allow the updating of values for the purposes of the application of the global taxes on the net assets or on the possession or possession of goods, the rates used in general for those purposes may be considered to update the costs of the goods specified in the first paragraph of this article.

For the purposes of the updates provided for in the preceding paragraphs, if the current costs or investments should be computed in Argentine currency, they shall be converted to the currency of the country in which the goods were located, placed or used economically, to the seller exchange rate considered in article 158, corresponding to the date of disposal of the goods referred to in articles 152 and 153. (Paragraph replaced by art. 74 of the Act No. 27.260 B.O. 22/7/2016. Watch: from the day after your publication in the Official Gazette.)

The value difference established following the update shall be added to the costs attributable to the assets, where applicable the application of the above paragraph, the value difference expressed in foreign currency shall be converted to Argentine currency, applying the exchange rate contemplated in the same for the date of completion of the period covered by the update.

With regard to goods for which the determination of the computable cost supports the deduction of amortizations, these will be calculated on the amount resulting from adding to their costs the differences of value from the authorized updates.

The treatment set out in this article should be supported by the fervent accreditation of those applied in foreign countries that enable them, as well as with the origin of the price indexes or coefficients used.

Provisions for third parties

Art. 155 - Where the residents included in article 119 (d) provide for third parties of funds affected by the generation of foreign source gains or from goods located, placed or used economically abroad, without such provisions responding to operations in the interest of the company, a foreign source gain equivalent to an interest with annual capitalization is presumed, without proof to the contrary, to be disclosed in the country that is not less than the largest established for commercial credits.

The same presumption shall be in respect of the provisions for third parties which, not responding to operations in their interest, make stable establishments defined in article 128 of funds or assets that are part of their assets, in which case the interest considered as a reference to the presumed gain shall be the greatest set for the purpose indicated in the preceding paragraph by the banking institutions of the countries in which they are installed.

This article shall not apply to the deliveries made to its partners by the companies covered by article 69, paragraph 2 (a), or to those which the said stable establishments make to their resident holders in the country, as well as to the provisions in respect of which article 130 applies.

Construction companies

Art. 156. - In the case of permanent establishments defined in article 128 carrying out the operations envisaged in article 74, for the purposes of the statement of the gross result, the provisions contained in the last article referred to shall apply, except for those included in the third paragraph of subparagraph (a) of its first paragraph and its third paragraph. Where such operations are carried out abroad by construction companies resident in the country, without their realization setting up a permanent establishment as defined in the preceding paragraph, the gross result shall be declared in the form set out in the fourth paragraph of that article 74. (Expression stable stability is replaced by permanent enlightenment, by art. 79 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Mines, quarries and forests

Art. 157 - In the case of mines, quarries and natural forests located abroad, the provisions contained in article 75 shall apply. Where, following the legal principles relating to the ownership of the subsoil, the first paragraph of that article is not applicable, the Federal Public Income Administration, autarchic entity within the Ministry of Economy and Works and Public Services, shall authorize other systems to consider the depletion of the productive substance, based on the value attributable to the subsoil before the exploitation begins.

With regard to natural forests, it would not rule under article 76.

Conversion

Art. 158 - With respect to the proceeds attributable to stable establishments defined in article 128, the currency operations of other computable countries to determine foreign source gains of residents in the country, shall be converted to Argentine currency to the type of exchange buyer or seller, as appropriate, in accordance with the quote of the Bank of the Argentine Nation at the end of the day on which the operations are implemented and in accordance with the provisions governing such changes.

When the operations covered in the preceding paragraph, or the credits originated for financing them, result in exchange differences, the same, established by annual revaluation of unpaid balances or by difference between the last valuation and the amount of the total or partial payment of the balances, shall be computed to determine the tax result of foreign source.

If the foreign exchange for the resident in the country originated the operations and credits referred to in the preceding paragraph, they are either entered into or disposed of in any form abroad by the same, the exchange differences that originate such facts will be included in their foreign source earnings..

Art. 159 - In the case of stable establishments covered by Article 128, the currency of the country in which computable operations are installed will be converted to determine the tax result expressed in other currencies, applying the type of exchange buyer or seller, as appropriate, in accordance with the quote of the banking institutions of that country at the end of the day on which the operations are completed.

Any transaction payable in currencies other than that of the country in which the establishment is located will be accounted for the actual payment, if it is a cash transaction, or for the day of entry, in the case of purchases, or departure, in the case of sales, in the case of credit operations.

Differences from operations that consider the preceding paragraphs or credits in currencies other than that of the country in which they are installed, originated to finance them, as set out in the second paragraph of the previous article, shall be computed to determine the tax result of permanent establishments. The same computation shall proceed with respect to the differences in exchange arising from the introduction to the country previously referred to in the currency originated by those operations or credits or their disposition in any form abroad. In no case will the exchange differences from operations or credits in Argentine currency be computed. (Expression stable stability is replaced by permanent enlightenment, by art. 79 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Where the establishments referred to in this article shall retract profits to their holders residing in the country, included in Article 119 (d) and (e), they shall, in order to establish their tax result for the period in which the respective receipt occurs, shall compute the exchange differences resulting from the comparison of the amount of the goods referred, converted to the type of exchange of the buyer provided in the first paragraph of the previous article, (Expression stable stability is replaced by permanent enlightenment, by art. 79 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

To that end, it is presumed, without admitting evidence to the contrary, that the recurring profits are attributable to the benefits obtained by the establishment in its last closed period prior to forwarding them or, if such an imputation was not possible or resulted in an excess of recurring profits, that the unencumbered amount is attributable to the immediate preceding or to the immediate preceding ones, considering first of all those whose closure is more forthcoming..

Chapter VI

Fourth category gains

Art. 160 - The net benefits of the contributions made by the insured are covered by article 79, which are derived from private retirement insurance schemes administered by constituted entities abroad or by stable establishments installed abroad by resident entities in the country subject to the control of the Superintendence of Insurance of the Nation, dependent on the Undersecretary of Banks and Insurance of the Ministry of Public Economic Policy Secretariat, as much as the Ministry of Economics and Works, 143

Art. 161 - Where the computation of the compensation referred to in the last paragraph of article 79 is appropriate, the totality of the compensations shall be considered, without prejudice to the deduction of the expenses reimbursed through them, which are duly documented and provided that those compensations, or the relevant part thereof, have been credited for reimbursement of such expenses..

Chapter VII

Deductions

Art. 162 - In order to determine the net gain of foreign source, the deductions admitted in Title III shall be effected, with the restrictions, adequacies and modifications set out in this chapter and in the form set out in the following paragraphs.

The admitted deductions will be subtracted from foreign source gains produced by the source that originates them. Individuals or indivisous successions residing in the country, as well as residents included in article 119 (d), (e) and (f), shall compute deductions originating abroad and in the country, in the latter case, considering the proportion that might correspond, except, where appropriate, to the stable establishments defined in article 128.

In order to establish the tax result of the stable establishments referred to in the preceding paragraph, they shall be subtracted from the proceeds attributable to them, the expenses required by them, the amortizations of the assets that make up their assets, affected to the production of such gains and the punishments admitted related to the operations they carry out and their staff.

The regulation shall establish the manner in which the gross gains shall be determined the deductible proportion in the case of deductions related to the obtaining of earnings from Argentine and foreign source and from foreign source taxed and non-taxed, including those exempted by this law and, in the case of human persons and indivisible successions, the one in which deductions imputable to profits from other sources of foreign origin shall be computed. (Expression is a visible existence, replaced by shihumans. by art. 79 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Art. 163 - With regard to foreign source gains, deductions authorized by articles 81, 82, 86 and 87 shall be applied with the following adequacies and without considering the updates that they may contemplate.

(a) With regard to article 81, it should be considered that:

1. Deductions authorized by subparagraphs (c) shall not be applicable, without the foreign source gains being computed to establish the limit set out in its first paragraph (e) and (g), second paragraph.

2. Contributions and discounts for retirement, pensions, withdrawals or subsidies from foreign States, their political subdivisions, international agencies to which the Nation is a party shall be deemed to be included in subparagraph (d), and, where required, those for social security institutions in foreign countries.

3. It is considered to be included in the first paragraph of subparagraph (g), compulsory discounts made abroad by application of the social security regimes of foreign countries.

(b) With regard to article 82, it should be considered that:

1. The regulation shall establish the incidence of deductions in accordance with subparagraphs (c) and (d).

2. Expenditures under subparagraph (e) may only be computed when properly documented.

(c) With regard to article 86, it should be considered that:

1. Recipients residing in the country of royalties of foreign source from the definitive or temporary transfer of goods -excluding stable establishments defined in article 128 - shall be governed by the provisions of this article, excluding the provisions of its second paragraph.

2. In the cases covered by subparagraph (a) of its first paragraph, the provisions of articles 152, 153 and 154 shall apply, as long as they are covered by subparagraph (b) of the same paragraph, the provisions of articles 164 and 165 shall be taken into account, in both cases, those which correspond to the nature of the property.

(d) With regard to article 87, it should be considered that:

1. For the determination of foreign proceeds not attributable to stable establishments defined in article 128, the deductions set out in this article shall be computed, to the extent and proportion applicable, without considering any updates that may be contemplated, excluding the forecasts and reserves covered, respectively, in subparagraphs (b) and (f), in the latter case where the compensation referred to in respect of foreign labour arrangements is to be paid,

2. For the purpose of determining the tax results of the stable establishments defined in article 128, the deductions authorized by this article shall be computed, with the limitation set out in the third paragraph of article 162, excluding the one set out in subparagraph (j), whereas the one included in subparagraph (d) shall be referred to the reservations that must be bindingly in accordance with the rules in the field in the countries in which there are extraordinary contributions,

Art. 164 - The amortizations authorized by article 81 (f) and wear amortizations referred to in article 82 (f) relating to assets affected by the acquisition of foreign proceeds shall be determined in the manner provided for in the first two (2) paragraphs of article 83 and article 84 (l), without contemplating the update provided by the same, in accordance with the nature of the amortizable goods.

In the case of amortizable movable goods imported from third countries to the one in which they are located, when their purchase price is higher than the wholesale price in force in the place of origin, plus the costs of transport and insurance to the last country, the provisions of the third paragraph of article 84, as well as the rule contained in its fourth paragraph, when commissions had been paid or credited to entities of the same economic group, intermediaries in the procurement operation, are any other.

Art. 165 - Where the countries in which the goods referred to in the preceding article are located, placed or used economically, or those in which the stable establishments defined in article 128 are installed, in their laws of the taxes analogous to the tax of this law, authorize the updating of the respective amortizations or take other measures of monetary correction that cause the same effect, the amortization quotas established as set out in the period of time,

In cases where the goods are not part of the assets of the stable establishments mentioned in the preceding paragraph, for the purpose of updating the same paragraph, the currentable amortization quotas shall be converted to the currency of the country in which the goods are located, placed or used economically, to the seller exchange rate set out in the first paragraph of Article 158 corresponding to the date on which the updated currency is finalized, as the date on which the change is made.

For the cases referred to in the third paragraph of article 154, the price indices used for the purposes of the global taxes on the net assets or possession or possession of property may be used to update the amortization quotas referred to in this article, considering the period specified in the first paragraph.

The provisions of this article can only be applied when the treatments adopted by foreign countries contemplated in this article are credited in a fruitful manner, as well as the price indices or coefficients considered by such treatments.

Deductions not admitted

Art. 166 - With regard to foreign proceeds, the provisions of article 88 shall, as applicable in that regard.

Notwithstanding the provisions of the preceding paragraph, the scope of the following subparagraphs of that article shall be established in the light of the following provisions:

(a) Subparagraph (b) includes capital interests invested by its resident headlines in the country to install stable establishments defined in Article 128;

(b) (d) includes taxes similar to the levy of this law applied abroad to foreign source earnings;

(c) They shall with respect to stable establishments defined in article 128, the regulatory limitations referred to in subparagraph (e), in relation to the remuneration paid by them originated by technical, financial or other advice provided from abroad..

Chapter VIII

Tax determination

Art. 167. - The tax attributable to the net gain of foreign source shall be established in the manner provided for in this article.

(a) The natural persons and indivisous successions residing in the country shall determine the tax corresponding to their net gain subject to Argentine source tax and that corresponding to the amount resulting from adding to it the net profit of foreign source, applying the scale contained in article 90. The difference that arises from subtracting the first of the second will be tax attributable to foreign source gains;

(b) Residents under Article 119 (d) and (f), shall calculate the tax for their net foreign source gain by applying the rate set out in Article 69 (a).

The tax attributable to foreign source gains resulting from the application of the rules contained in paragraphs (a) and (b) above shall be deducted, first, from analogous tax credits regulated in chapter IX.

Chapter IX

Tax credit effectively paid abroad

Art. 168 - From the tax of this law for foreign source gains, the residents of the country covered by Article 119 shall deduct, to the limit determined by the amount of such tax, a credit for the analogous national levies actually paid in the countries in which such profits are obtained, calculated in accordance with this Chapter.

(Article replaced by Act No. 25,239, Title I, art.1°, subparagraph (x). - Watch: From 31/12/99, the exercises starting from that date will take effect. )

Art. 169 - Taxes similar to that of this law are considered, which impose the profits covered by Article 2 as they grave net income or accrue deductions that allow the recovery of the computable significant costs and expenses to determine it. They are covered by the expression " similar taxes " , the retentions which, as a single and definitive payment, apply the countries of origin of the gain in the head of the beneficiaries residing in the country, provided that they are taxed in the term, in accordance with what is considered in this article.

(Article replaced by Act No. 25,239, Title I, art.1°, subparagraph (y). - Watch: From 31/12/99, the exercises starting from that date will take effect. )

Art. 170 - Taxes referred to in the previous article are effectively paid when they have been entered into the fiscos of the foreign countries that apply them and are supported by the respective taxpayers, including, where appropriate, the income of advances and retentions that, in relation to these taxpayers, are applied on a payment basis to their account, up to the amount of the tax.

Except where a different treatment is expressly provided in this chapter, the analogous taxes will be converted to Argentine currency to the type of purchaser exchange, in accordance with the quote of the Bank of the Argentine Nation, at the end of the day when its actual payment occurs, in accordance with the rules and provisions governing the changes in its opportunity, computing to determine the credit of the fiscal year in which such payment takes place.

Art. 171 - Residents in the country, holders of stable establishments defined in Article 128, shall compute the similar taxes effectively paid by such establishments on the tax result of the same, which those have included in their foreign source earnings.

Where the tax result of the aforementioned establishments, determined in the country of installation by the application of the rules in force therein, includes profits established by this law as an Argentine source, the similar taxes paid in that country, shall be adjusted by excluding the share of the same ones that correspond to those gains. To this end, it will apply to the paid tax, increased in the credit that would have been granted by the tax tax in the Argentine Republic, the proportion resulting from relating the gross proceeds of Argentine source considered to determine that result with the total gross proceeds computed to the same effect.

If the tax determined in accordance with the provisions of the preceding paragraph exceeds that provision, the latter shall be subtracted from the former to establish the analogous tax actually paid to deduct.

If the countries where stable establishments are located tax the proceeds attributable to them, obtained in third countries and awarded credit for the taxes actually paid in such countries, the tax offset by such credits shall not be computed to establish the tax paid in the former.

The computable analog tax actually paid in the installation country will become the form indicated in article 170, except in the case of advances and retentions contemplated by this article, which will be converted to the exchange rate indicated in the same, corresponding to the day of completion of the establishment to which they correspond. The income of the balance to be paid arising from the affidavit filed in the country previously referred to, shall be charged to the fiscal year in which the result of the establishment must be included, provided that such income is made prior to the expiry set for the presentation of the affidavit of its resident holders.

Similar taxes effectively paid by establishments in other foreign countries in which they obtained the income that is attributable to them and which have been imposed in the country in which they are installed, shall be charged against the tax applied in the country, corresponding to foreign source incomes, converted to the exchange rate indicated in the preceding paragraph corresponding to the day considered by the country of installation to convert them to the currency of the same. Equal treatment shall be waived to the analogous taxes that stable establishments would have paid on the same profits when they are not subject to tax in the country of installation, in which such tax shall be converted to Argentine currency to the same exchange rate corresponding to the closing day of the annual year of establishments.

The additional provisions to be applied by the countries in which stable establishments on recurring or credited profits are located shall be treated in accordance with the provisions of the last paragraph of Article 170.

Art. 172 - If the entities covered by article 133 (d), (e) and (f) are constituted, domiciled or located in countries that submit to the imposition of their results, their shareholders, partners, shareholders, holders, control or beneficiaries, resident in the country shall compute the similar taxes effectively paid by corporations and other external entities, to the extent that they result from applying to them the proportion that they should consider. The income of the tax thus determined shall be attributed to the fiscal year to which the proceeds that originate must be charged, provided that it takes place before the expiry set for the presentation of the affidavit of the shareholders, shareholders, holders, controllers or resident beneficiaries, or the presentation of the tax, if it is made before the expiration occurs.

When those countries only earn profits distributed by societies and other entities considered in this article, the similar taxes applied on them will be attributed to the fiscal year in which their payment occurs. The same criterion shall apply to similar taxes applied by those countries on such distributions, even if they adopt the treatment considered in the preceding paragraph with respect to such entities.

(Article replaced by art. 78 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Art. 173 - Where the application of the provisions of the last paragraphs of articles 171 and 172, it shall be presumed, without admitting evidence to the contrary, that the remessed or distributed profits are attributable to the immediate exercise prior to that in which the remesa or distribution is made. If such an imputation is not possible or would result in an excess of recurring or distributed utilities, the unencumbered amount will be attributed to the previous immediate exercises, first considering the ones closest to the one in which the remesa or distribution took place.

Art. 174 - Residents in the country who are required to liquidate the analogous tax in the foreign country by affidavit in which they are required to determine their overall net income, shall establish the computable portion of the tax by applying the percentage resulting from relating the gross gains obtained in that country and taxable for the purposes of this law, with the total gross gains included in the said declaration

If the foreign country encumbers gains obtained outside its territory, the tax offset by the credits paid by the foreign country for similar taxes shall not be considered for the purpose of establishing its analogous tax. This is without prejudice to the appropriate computation with respect to the similar taxes paid in third countries in which the income taxed by that foreign country is obtained.

Art. 175 - When residents in the country pay similar tax differences originating from the countries that applied them, which involve an increase in credits computed in fiscal years prior to that in which payment was made, such differences will be charged to the fiscal year in which they are paid.

Art. 176 - In cases in which foreign countries recognize, by the channels provided for in their legislation, excesses of similar tax payments entered by residents in the country or by their stable establishments defined in Article 128 and that recognition supposes a decrease in similar tax credits computed by such residents in previous fiscal years or to which it is applicable in the fiscal year in which it took place, such excesses, converted to Argentine currency at the rate of exchange. This, without prejudice to the fact that the effect of the excesses recognized in the payment of the analogous taxes of the respective countries, converted to Argentine currency to the same type of exchange, are computed to establish the tax analogous to which income is imposed.

Art. 177 - Corporations and companies or single-person exploitations referred to in Article 150 shall, to the extent appropriate to their partners or owners, attribute the analogous taxes actually paid abroad following the receipt of foreign source earnings, including those paid by their stable establishments installed abroad, for their tax result from the same source.

Art. 178 - If the equivalent computable taxes could not be compensated in the fiscal year to which they are charged for exceeding the tax of this law for the net profit of foreign source attributable to that same year, the unrepaired amount may be deducted from the tax attributable to the net profits of that source obtained in the five (5) immediate fiscal years following the previous audit. After the last of those years, the undeducted balance shall not be subject to any compensation.

Art. 179 - Residents in the beneficiary country in other countries of special or promotional measures that involve the total or partial recovery of the actually paid analogue tax should reduce the credit generated or generated, to the extent of that recovery.

Chapter X

Transitional arrangements

Art. 180 - In the case of residents of the country receiving from foreign States, their political subdivisions, social security institutions abroad or international agencies to which the Nation is a party, pensions, rents or subsidies that have their origin in personal work and, before they give effect to the provisions of this title, they would have made, in whole or in part, contributions to the funds intended for their payment, through contributions or discounts.

When, before the effects referred to in the preceding paragraph, they would have received gains under this article, the deduction that the same authorises shall be effected only until the proportion of the amount that corresponds to the gains that are realized after the preceding time, which shall be determined in the manner in which the regulation is established.

For the purpose of calculating deduction, the capital contributed or, if any, the deductible proportion will be converted to Argentine currency at the date of payment of profit.

In addition, for the purpose of establishing the proportion referred to in the second paragraph of this article, the contributed capital shall be converted to Argentine currency at the date on which the provisions of this title begin to cause effect.

Art. 181 - The provisions of article 159, paragraphs 4 and 5, shall apply only to exchange differences arising from remittances made by stable establishments that are required by their holders to impute closed periods after the time when the provisions of this title are effective.

Art. 182 - The presumption set out in article 173, does not include the distributed or remonthly profits attributable to closed periods prior to the effect of the provisions of this title.

(Note Infoleg: They have been replaced in the present updated text, the expression “visible existence” by “syphims”; the expressions “physical person” by “human person”; and “stable enlightenment” by “permanent enlightenment” by art. 79 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Law)

Background

- Article 95, last paragraph incorporated by art. 65 of the Act No. 27.430 B.O. 29/12/2017. Watch: the day following the date of its publication in the Official Gazette and will come into effect in accordance with the provisions of each of the Titles that make up it. See art. 86 of the Reference Act;

- Article 104 (Note Infoleg: by art. 9th of the Act No. 27.346 B.O. 27/12/2016 it is stated that, thirty-three percent (33%) of the resources provided for in paragraph 1 (c) of the first paragraph of Article 104 of the Law of Taxation, text ordered in 1997 and its modifications, will be distributed directly to the whole of the provinces according to the indexes provided for in the Law of Federal Coparticipation of Taxes, Law 23.548 and its modifications, with the effects necessary Monitoring: from publication in the Official Gazette.

- Article 90, sixth paragraph repealed by art. 75 of the Act No. 27.260 B.O. 22/7/2016. Watch: from the day following the date of publication in the Official Gazette;

Article 23 (a) replaced by art. 1 Decree No. 394/2016 B.O. 23/2/2016. Vigilance: from 1 January 2016, inclusive;

- Article 23, paragraph (b) replaced by art. 1 Decree No. 394/2016 B.O. 23/2/2016. Vigilance: from 1 January 2016, inclusive;

- Article 23, paragraph (c), paragraph replaced by art. 1 Decree No. 394/2016 B.O. 23/2/2016. Vigilance: from 1 January 2016, inclusive;

- Article 23 (Note Infoleg: by art. 1 Decree No. 152/2015 B.O. 18/12/2015 increases, in respect of the incomes referred to in Article 79 (a), (b) and (c) of the Law on Taxation, which was ordained in 1997 and its modifications, the special deduction set out in paragraph (c) of this Article, to an amount equivalent to the net amount of the second supplementary annual grant quota for the year 2015.
For the purpose of obtaining such a net amount, the amounts of contributions corresponding to the PREVISIONAL INTEGRADE SYSTEM Ao, in its case, those corresponding to provincial, municipal or other boxes, to the NATIONAL INSTITUTE OF SOCIAL SERVICES FOR JUBILADOS AND PENGES Monitoring: from the day of publication in the Official Gazette);

- Article 23, (Note Infoleg: by art. 5° Decree No. 152/2015 B.O. 18/12/2015 increases, for the fiscal period 2015, in respect of the incomes mentioned in Article 79 (a), (b) and (c) of the Law on Taxation, text ordered in 1997 and its modifications, the deductions provided for in paragraphs (a), (b) and (c) of the application of this article, to the sums established under the conditions and for the universe of taxpayers, Monitoring: from the day of publication in the Official Gazette);

- Article 23, (Note InfolegSee General Resolution No. 3770/2015 of the AFIP B.O. 7/5/2015, by which it is stated that the retention agents reached by General Resolution No. 2.437, their modifications and supplements, for the purpose of the application of the regime in it must observe son remuneration and/or assets received from 1 January 2015including what is provided in the reference rule. Monitoring: from the day of its publication in the Official Gazette, including, and will take effect from the fiscal period 2015, inclusive);

- Article 23, (Note Infoleg: by art. 1 Decree No. 2354/2014 B.O. 12/12/2014 increases, in respect of the incomes mentioned in article 79 (a), (b) and (c) of the Law on Taxation, ordained text in 1997 and its modifications, the special deduction set out in subparagraph (c) of this article, to an amount equivalent to the net amount of the second quota of the Supplementary Annual Grant. For the purpose of obtaining the net amount, the amounts of contributions corresponding to the Argentinean Integrated Provision System shall be detracted from the gross amount of the second instalment of the Annual Supplementary Grant loso, if any, those corresponding to provincial, municipal or other boxes, to the National Institute of Social Services for Retired and Pensioned, to the National System of Social Works and to regular union quotas.
The provisions of the previous article will have an effect solely on the second instalment of the Supplementary Annual Allowance for the year 2014 and for the subjects whose highest monthly gross remuneration, from July to December 2014, does not exceed the amount of TREINTA PESOS and CINCO MIL ($ 35,000). Monitoring: from the day of publication in the Official Gazette);

Article 2 (3) replaced by art. 1 Act No. 26.893 B.O. 23/09/2013. Vigilance: from its publication in the Official Gazette and will apply to the imponible facts that are perfected from the aforementioned validity;

Article 45, subparagraph (k) replaced by article 3 of the Act No. 26.893 B.O. 23/09/2013. Vigilance: from its publication in the Official Gazette and will apply to the imponible facts that are perfected from the aforementioned validity;

- Article 90, sixth paragraph pursuant to the proposed replacement by art. 4° of the Act No. 26.893 B.O. 23/09/2013. Vigilance: from its publication in the Official Gazette and will apply to the imponible facts that are perfected from the aforementioned validity;

- Article 90, paragraphs replaced by art. 4° Act No. 26.893 B.O. 23/09/2013. Vigilance: from its publication in the Official Gazette and will apply to the imponible facts that are perfected from the aforementioned validity;

- Article 90, paragraphs in accordance with the substitution provided by art. 4° of the Act No. 26.893 B.O. 23/09/2013. Vigilance: from its publication in the Official Gazette and will apply to the imponible facts that are perfected from the aforementioned validity;

- Article 23, (Note Infoleg: by art. 1 Decree No. 1242/2013 B.O. 28/08/2013 increases with respect to the incomes referred to in article 79 (a), (b) and (c) of the Gain Tax Act, a text ordained in 1997, and its modifications, the special deduction set out in subparagraph (c) of this article, up to an amount equivalent to the amount that arises from subtracting to the net profit subject to tax the deductions of subparagraphs (a) and (b) of article 23. The provisions of Article 1 shall have an effect only for those subject whose highest remuneration and/or monthly gross accrued between January and August 2013, shall not exceed the amount of PESOS QUINCE MIL ($15,000). Monitoring: implementation from 1 September 2013, inclusive);

- Article 23, (Note Infoleg: by art. 4° and 5° Decree No. 1242/2013 B.O. 28/08/2013 states that the deductions set out in subparagraphs (a), (b) and (c) of this Article shall be increased in a VEINTE BY CIENTO (20%) when the profits referred to in Article 79 (a), (b) and (c) of that Law. This will have an effect only for those who have the highest monthly pay and/or gross earned between January and August 2013, not exceeding the sum of VEINTICINCO MIL ($ 25,000). Monitoring: implementation from 1 September 2013, inclusive);

- Article 23, (Note Infoleg: by art. 6° Decree No. 1242/2013 B.O. 28/08/2013 states that the deductions set out in subparagraphs (a), (b) and (c) of this Article shall be increased in a TREINTA BY CIENTO (30%) in the case of the gains referred to in Article 79 (a), (b) and (c) of the said Law, whose beneficiaries are employed in relation to dependency that work and retirees living in the Provinces and, as appropriate, Article No. Monitoring: implementation from 1 September 2013, inclusive);

- Article 23, (Note Infoleg: by art. 1 Decree No. 1006/2013 B.O. 26/7/2013 increases, in respect of the incomes mentioned in article 79 (a), (b) and (c) of the Vocational Tax Act, a text ordered in 1997, and its modifications, the special deduction set out in subparagraph (c) of this article, to an amount equivalent to the net amount of the first supplementary annual grant.
For the purpose of obtaining the net amount, the amounts of contributions corresponding to the Argentinean Integrated Provision System shall be detracted from the gross amount of the first instalment of the Annual Supplementary Grant loso, if any, those corresponding to provincial, municipal or other boxes, to the National Institute of Social Services for Retired and Pensioned, to the National System of Social Works and to regular union quotas.
The provisions of the previous article will have an effect only for the first quota of the Supplementary Annual Allowance for 2013 and for the subjects whose highest monthly gross remuneration, from January to June 2013, does not exceed the amount of VEINTICINCO MIL PESOS ($ 25,000). Watch: from the day of publication in the Official Gazette. See Previous Increase: art. 1 Decree No. 2191/2012 B.O. 15/11/2012);

Article 23 (a) replaced by art. 1 Decree No. 244/2013 B.O. 5/3/2013. Monitoring: from 1 March 2013, inclusive;

- Article 23, paragraph (b) replaced by art. 1 Decree No. 244/2013 B.O. 5/3/2013. Monitoring: from 1 March 2013, inclusive;

- Article 23, paragraph (c) First paragraph replaced by art. 1 Decree No. 244/2013 B.O. 5/3/2013. Monitoring: from 1 March 2013, inclusive;

Article 23 (a) replaced by article 2 (a) Act No. 26.731 B.O. 28/12/2011. Vigilance: implementation from the fiscal period 2011, inclusive;

- Article 23, inc. (b) replaced by article 2 (a) Act No. 26.731 B.O. 28/12/2011. Vigilance: implementation from the fiscal period 2011, inclusive;

- Article 23, inc. b) pto.1 , replaced by article 2 (a) Act No. 26.731 B.O. 28/12/2011. Vigilance: implementation from the fiscal period 2011, inclusive;

- Article 23, inc. b) pto.2 , amount replaced by article 2 (a) Act No. 26.731 B.O. 28/12/2011. Vigilance: implementation from the fiscal period 2011, inclusive;

- Article 23, inc. b) pto.3 , amount replaced by article 2 (a) Act No. 26.731 B.O. 28/12/2011. Vigilance: implementation from the fiscal period 2011, inclusive;

Article 23, inc. (c), amount replaced by article 2 (a) Act No. 26.731 B.O. 28/12/2011. Vigilance: implementation from the fiscal period 2011, inclusive;

- Article 23, paragraph (c), expression "STEMA INTEGRADO DE JUBILATIONS AND PENSIONS" replaced by the expression "Argentine Integrated System" by art. 2nd subparagraph (b) Act No. 26.731 B.O. 28/12/2011. Vigilance: implementation from the fiscal period 2011, inclusive;

- Article 23, (Note Infoleg: by art. 1 Act No. 26.731 B.O. 28/12/2011, for the fiscal period 2010, the amounts provided for in this article are considered to be applicable, as follows: (a) Ten thousand eight hundred pesos ($ 10.800); (b) Ten thousand eight hundred pesos ($ 10.800); item 1 of subparagraph (b) Twelve thousand pesos ($ 12,000); item 2 of subparagraph (b) Six thousand pesos ($ 6,000);

Article 20, subparagraph (l) repealed by article 2 of the Act No. 26.545 B.O. 2/12/2009 Relevance: from the day of its publication in the Official Gazette, and effect for fiscal exercises that close from 1 January 2010, inclusive;

- Article 20 (l) Note Infoleg: by art. 1st of the Act No. 26.455 B.O. 16/12/2008, is extended until 31 December 2009, including the suspension of the waiver set out in this paragraph . referred to as (1) in the Reference Act .. Vigencia: from the day of its publication in the Official Gazette and there will be effects on export applications for consumption registered in the Directorate General of Customs of the Federal Public Income Administration, an autonomous entity within the Ministry of Economy and Production, from 1 January 2009, inclusive. Previous: Act No. 26,347 B.O. 15/1/2008; Act No. 26.180 B.O. 20/12/2006; Act No. 26.073 B.O. 10/1/2006; Act No. 25.988 B.O. 31/12/2004; Act No. 25.868 B.O. 8/1/2004;

- Article 23 (c), Amount replaced by art. 1 Decree No. 1426/2008 B.O. 9/9/2008. Monitoring: from the day of publication in the Official Gazette and effects will arise from the current fiscal period, including;

Article 23 (b), item 3, Amount replaced by art. 1 Decree No. 1426/2008 B.O. 9/9/2008. Monitoring: from the day of publication in the Official Gazette and effects will arise from the current fiscal period, including;

Article 23, paragraph (b), item 2, Amount replaced by art. 1 Decree No. 1426/2008 B.O. 9/9/2008. Monitoring: from the day of publication in the Official Gazette and effects will arise from the current fiscal period, including;

Article 23 (b), item 1, Amount replaced by art. 1 Decree No. 1426/2008 B.O. 9/9/2008. Monitoring: from the day of publication in the Official Gazette and effects will arise from the current fiscal period, including;

- Article 23 (b) Amount replaced by art. 1 Decree No. 1426/2008 B.O. 9/9/2008. Monitoring: from the day of publication in the Official Gazette and effects will arise from the current fiscal period, including;

- Article 23 (a), Amount replaced by art. 1 Decree No. 1426/2008 B.O. 9/9/2008. Monitoring: from the day of publication in the Official Gazette and effects will arise from the current fiscal period, including;

- Article 23, inc. (b) replaced by art. 1 Act No. 26.287 B.O. 30/8/2007. Implementation from fiscal year 2007, with effect from 1 January 2007;

- Article without number incorporated after art. 23, replaced by article 3 of the Act No. 26.287 B.O. 30/8/2007. Implementation from fiscal year 2007, with effect from 1 January 2007;

- Article 23, paragraph (c), paragraph replaced by art. 2° Act No. 26.287 B.O. 30/8/2007. Implementation from fiscal year 2007, with effect from 1 January 2007;

Article 23 (a) sum replaced by art. 1 Decree No. 298/2007 B.O. 29/3/2007. Monitoring: the day of publication in the Official Gazette and will have effects from the current fiscal period to that date;

- Article without number incorporated after article 23, Value of sections first and second, replaced by art. 1 Decree No. 298/2007 B.O. 29/3/2007. Monitoring: the day of publication in the Official Gazette and will have effects from the current fiscal period to that date;

Article 23 (b), sums replaced by art. 1 Decree No. 298/2007 B.O. 29/3/2007. Monitoring: the day of publication in the Official Gazette and will have effects from the current fiscal period to that date;

- Article 23 replaced by art. 1 Decree No. 314/2006 B.O. 22/3/2006. Watch: from the day of publication;

- Article without number incorporated after article 23, replaced by art. 2nd Decree No. 314/2006 B.O. 22/3/2006. Watch: from the day of publication;

-Note Infoleg: - By Art. 76 of the Act No. 26.078 B.O. 12/1/2006 provides as follows: "Progress during the validity of the respective taxes, or until the sanction of the Federal Co-participation Act, which establishes article 75, paragraph 2, of the National Constitution, which first occurs, the distribution of the proceeds of the taxes provided for in Laws Nos. 24.977, 25.067 and its amendments, the Law on the Tax of Wins (t. 1997 and its amendments), 24.130, 23.966 (t. 1997 and its amendments), 24.464 ; Article 5° ,, 24.699 and amendments, 25.226 and amendments and 25.239 , Article 11 ,, amended by Law No. 24.625

- Article 23, last paragraph incorporated by art. 1 Act No. 25.987 B.O. 11/1/2005. Vigilance: from the day of its publication in the Official Gazette and effect for the fiscal periods ending from that date inclusive;

- Article 15, paragraphs incorporated by art. 2° of the Act No. 25.784B.O. 22/10/2003. - Watch: From the day of publication in B.O.;

- Article 18, last paragraph replaced by article 3 of the Act No. 25.784B.O. 22/10/2003. - Watch: From the day of publication in B.O.;

Article 20, subparagraph (w) replaced by article 2 of the Act No. 26.893 B.O. 23/09/2013. Vigilance: from its publication in the Official Gazette and will apply to the imponible facts that are perfected from the aforementioned validity;

- Article 20 (l) Note Infoleg: By art. 1 Act No. 25.731 B.O. 7/4/2003 is suspended until 31 December 2003, the exemption provided for in this paragraph como referred to as (1) in the Reference Act . . The suspension shall reach all export refunds, including reimbursements provided for in Act No. 23.018 and its amendments, and shall be effective in respect of export applications for consumption recorded in the National Customs Administration from the entry into force of the reference law;

- Article 81 (c), first paragraph replaced by art. 65 of the Act No. 25.600 B.O. 12/6/2002;

- Article 105: La La Act No. 25.558 B.O. 8/1/2002, art. 1st is extended until 31 December 2005 the validity of this Law. Monitoring: from 1 January 2002, inclusive;

- Article 23 (b), subparagraph (3), replaced by art. 1 Decree No. 860/2001 B.O. 2/7/2001. Monitoring: from the current fiscal year to the date of publication of Decree 860/2001;

Article 23 (c), replaced by art. 1 Decree No. 860/2001 B.O. 2/7/2001. Monitoring: from the current fiscal year to the date of publication of Decree 860/2001;

- Article 81, third paragraph (a), replaced by art. 2nd Decree No. 860/2001 B.O. 2/7/2001;

- Article 90, third paragraph incorporated by art. 3rd p. (e) Decree No. 493/2001 B.O. 30/4/2001. Watch: from publication. Effect for the current fiscal year on the date of publication of the decree;

- Article 90, second paragraph incorporated by article 3, paragraph (e) Decree No. 493/2001 B.O. 30/4/2001. Watch: from publication. It will be effective for transactions whose payment is made from the date of entry into force of the dto. 493/2001;

- Article s/n incorporated following article 48, by art. 3° pto. d) Decree No. 493/2001 B.O. 30/4/2001. Monitoring: for the current fiscal year to the date of publication of the decree;

- Article 45, inc. (k) incorporated by art. 3°(c) Decree No. 493/2001B.O. 30/4/2001. Watch: from publication. Effect for the current fiscal year on the date of publication of the decree;

- Article 20, inc. w) replaced by art. 3°(b) Decree No. 493/2001 B.O. 30/4/2001. Watch: from publication. Effect for the current fiscal year on the date of publication of the decree;

- Article 19, paragraph replaced by article 3 (a) Decree No. 493/2001 B.O. 30/4/2001. Monitoring: for the current fiscal year to the date of publication of the decree;

Article 2, paragraph (3) replaced by art. 7° Act No. 25.414 B.O. 30/3/2001;

- Article 20, first paragraph, inc. w) first paragraph, replaced by art. 7th of the Act No. 25.414 B.O. 30/3/2001;

Article 81 (a), paragraph replaced by Act No. 25.402Art. 3, subparagraph (c), B.O. 12/1/2001.- Proceedings: From 12/1/2001 and effective from the entry into force of this Act;

- Article 81, subparagraph (a) Act No. 25.402 Art. 3 (b), B.O. 12/1/2001.- Proceedings: Starting from 12/1/2001, and will be effective for debts due to mortgage loans issued as of 1 January 2001, inclusive;

Note Infoleg: - For Art. 3rd of the Act No. 25,400 B.O. 10/1/2001 provides as follows: "Progress until 31 December 2005 or until the sanction of the Federal Co-participation Act which establishes article 75, paragraph 2, of the NATIONAL CONSTITUTION, the distribution of the tax produced in the Nros Act. 24.977, 25.067, 24.464, 20.628 (T. 1997 and its amendments), 23.966 (T. 1997 and its amendments), 24.130, 24.699, 24.919, 25.063, 25.082 with suspension of article 3, 25,226 and 25,239 under article 75, paragraph 3, of the NATIONAL CONSTITUTION";

- Article 23 replaced by Act No. 25,239, B.O. 31/12/1999, Title I, art.1°, subparagraph (j). - Watch: From 31/12/99 and effective 1/1/2000;

- Article 20 (f) second paragraph replaced by Act No. 25,239, Title I, art.1°, subparagraph (e). - Vigilance: From 31/12/99 and effect for the exercises starting from that date;

Article 20, subparagraph (k) replaced by Act No. 25,239, Title I, art.1°, subparagraph (f). - Vigilance: From 31/12/99 and effect for the exercises starting from that date;

- Article incorporated after article 23 by Act No. 25,239, B.O. 31/12/1999, Title I, art.1°, subparagraph (k). - Watch: From 31/12/99 and effective 1/1/2000;

- Article 135 replaced by Act No. 25,239, Title I, art.1°, subparagraph (u). - Vigilance: From 31/12/99 and effect for the exercises starting from that date;

- Article 133 replaced by Act No. 25,239, Title I, art.1°, subparagraph (t). - Vigilance: From 31/12/99 and effect for the exercises starting from that date;

Article 81 (g) replaced by Act No. 25,239, Title I, art.1°, subparagraph (l). - Watch: From 31/12/99 and effective 1/1/2000;

- Article 81 (h) incorporated Act No. 25,239, Title I, art.1°, subparagraph (m). - Watch: From 31/12/99 and effective 1/1/2000;

- Article 90, Scale replaced by Act No. 25,239, Title I, art.1°, subparagraph (o). - Watch: From 31/12/99 and effective 1/1/2000;

- Article 105: The Act No. 25,239 B.O. 31/12/1999, Part XII, Article 14, extends until 31 December 2001 the validity of this Act;

- Article 8, replaced by Act No. 25,239, B.O. 31/12/1999, Title I, art.1°, subparagraph (a). - Vigilance: From 31/12/99 and effect for the exercises starting from that date;

- Article 15, replaced by Act No. 25,239, Title I, art.1°, subparagraph (c). - Vigilance: From 31/12/99 and effect for the exercises starting from that date;

- Article s/n incorporated after art. 15 replaced by Act No. 25,239, Title I, art.1°, subparagraph (d). - Vigilance: From 31/12/99 and effect for the exercises starting from that date;

- Article 20, first paragraph, inc. w), second paragraph incorporated by Act No. 25.057 B.O. 6/1/1999, art. - Proceedings: From 6/1/99, and effect will arise from the validity of Chapter III of Law No. 23.696;

- Article s/n incorporated after art. 118 Act No. 25.063, Title III, art.4°, subparagraph (z) d. - Proceedings: From its publication in the Official Gazette and effect will be given to the periods that close after the entry into force of this law or, if any, the current fiscal year to that date;

- Article 90, Scale replaced by Act No. 25.063, B.O. 30/12/1998, Title III, art.4°, subparagraph w);

- Article 93 (c), replaced by Act No. 25.063, B.O. 30/12/1998, Title III, art.4°, subparagraph (z) to one). - Watch: From 31/12/98;

- Article 81 (a) Act No. 25.063, B.O. 30/12/1998, Title III, art.4°, subparagraph s). - Proceedings: From its publication in the Official Gazette and effect will be given to the periods that close after the entry into force of this law or, if any, the current fiscal year to that date;

Article 70, subparagraph (c), Act No. 25.063, Title III, art.4°, subparagraph (q). - Watch: From 31/12/98;

- Article 71, Rate established by Act No. 25.063, Title III, art.4°, subparagraph (q). - Watch: From 31/12/98;

- Article 49, subparagraph (s/n) Act No. 25.063, Title III, art.4°, subparagraph (n). - Proceedings: From its publication in the Official Gazette and effect will be given to the periods that close after the entry into force of this law or, if any, the current fiscal year to that date;

- Article 46 replaced by Act No. 25.063, Title III, art.4°, subparagraph (m). - Watch: From 31/12/98;

- Article 37, established rate Act No. 25.063, Title III, art.4°, subparagraph (k). - Proceedings: From its publication in the Official Gazette and effect will be given to the periods that close after the entry into force of this law or, if any, the current fiscal year to that date;

- Article 20, paragraph following subparagraph (h) by Act No. 25.063 B.O. 30/12/1998, Title III, art.4°, subparagraph (g). - Watch: From 1/1/99;

- Article 19, paragraphs incorporated by Act No. 25.063, Title III, art.4°, subparagraph (e). - Watch: From 31/12/98;

- Article 97 (a) replaced by Act No. 25.063 B.O. 30/12/1998, Title III, art.4°, subparagraph (z)(c)). - Watch: From 31/12/98;

- Article 81, inc.a) last paragraph incorporated by Act No. 25.063 B.O. 30/12/1998, Title III, art.4°, subsection (s). - Proceedings: From its publication in the Official Gazette and effect will be given to the periods that close after the entry into force of this law or, if any, the current fiscal year to that date;

- Article 81, paragraph incorporated by Act No. 25.063, B.O. 30/12/1998, Title III, art.4°, subparagraph s). - Proceedings: From its publication in the Official Gazette and effect will be given to the periods that close after the entry into force of this law or, if any, the current fiscal year to that date;

- La Act No. 24.919 B.O. 31/12/1997, art. 1 extended until March 31, 2000 the validity of this law;

- Article 104, (Expression "31 December 1998" replaced by "31 December 1999", by Act No. 24.919(B.O. 31/12/97). Vigilance: from 1 January 1998, inclusive;

- Article 23, (NoteSee R.G. N° 4.166 on the Optional Reliquidation Regime for the fiscal period 1995.