i.        The problematic In June 2019, the Japanese and Argentine governments signed a Double Tax Convention for the Elimination of Double Taxation on Income Taxes and the Prevention of Tax Evasion and Avoidance (hereinafter Argentina-Japan DTA).[1] Although the goal of this international instrument, like all double tax treaties, is to generate an environment conducive to…

Nothing changed but the change Despite several changes were introduced to Chapter I and Chapter VI of the 2017 OECD Guidelines on intangibles in accordance with Actions 8-10 BEPS Final Reports to align taxing rights and value creation, those changes were not substantial to permit an application of the ALP that will prevent profit shifting…