On 29 September 2025, Argentina deposited with the Organisation for Economic Co-operation and Development (OECD) the ratification instrument for the "Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting" (Multilateral Instrument or MLI). With this step completed, the MLI will enter into force for Argentina on 1 January 2026.

It should be noted that the MLI was executed in France on 24 November 2016, as part of the Base Erosion and Profit Shifting (BEPS) Action Plan promoted by the OECD and the G20. Argentina signed the MLI on 7 June 2017, and it was approved by Congress through Law 27,788 published in the Official Gazette on 28 May 2025. (For background, see EY Global Tax Alerts, Argentina enacts Multilateral Instrument law, dated 30 May 2025, Argentine Senate approves Multilateral Instrument, dated 9 May 2025, and Argentine Chamber of Deputies approves Multilateral Instrument and other tax treaties, dated 9 October 2024.)

The MLI allows for changes to be introduced in the existing network of double taxation agreements (DTTs) without the need to renegotiate each treaty bilaterally. In general terms, it enables the incorporation of anti-abuse clauses, improves the definition of permanent establishment and optimizes dispute resolution mechanisms between countries.

Multinational companies with a presence in Argentina should consider the changes the MLI introduces to the existing network of DTTs and assess the possible consequences for their cross-border transactions.