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Decree No. 382/2019 (the 'Decree') was published in the Official Gazette on May 29, 2019, regulating the tax treatment mentioned on Law No. 27,440 created to boost capital investments and the development of real estate and infrastructure projects.

1. In the case of fideicomisos and fondos comunes de inversión (FCI) whose purpose is (i) developing and/or direct investment on real estate, agricultural, forest and/or infrastructure projects; and/or (ii) the financing or the investment on any kind of project, company or assets through marketable securities or any other type of instrument, certificate, derivative agreements, participation or association, in any of its variations and/or combinations, the fideicomisos and FCI will not pay Income Tax on its Argentine source income as long as the total amount of securitized debt, participation certificates and quotas issued by these fideicomisos and FCI, respectively, have been subject to public offering with the previous approval of the Argentine Security and Exchange Commission (CNV). This benefit will not be applicable to foreign sourced income, which will be subject to Income Tax.

Investors that are resident in Argentina and foreign beneficiaries will pay Income Tax at the rates set forth by the Income Tax Law when they collect the income. Income collection will have to be considered upon its distribution by the fideicomiso or the FCI. Capitalization of dividends by participation certificates or quotas delivered to the investor implies the distribution and collection of the income.

If the total amount of securitized debt and/or participation certificates and/or quotas issued by these fideicomisos and FCI, respectively, have not been placed by a public offering authorized by the CNV, the fideicomisos and FCI will pay Income Tax on its Argentine and foreign sourced income.

2. In the case of fideicomisos and closed FCI whose purpose is (i) real estate development for social housing and medium and low income groups; and/or (b) mortgages loans, and/or (c) mortgage values, the fideicomisos and closed FCI will not pay income tax as long as all the participation certificates and/or quotas issued by these fideicomisos and closed FCI, respectively, have been placed by public offering with the previous approval of the CNV.

The effective taxation rate will be determined by the term of the project and meeting certain requirements, as follows:

Term below 5 years: from 5% to 35% (Individuals and Estates), 31.5% (Foreign Beneficiaries).

Term between 5 and 10 years: 15% (Individuals and Estates), 13.5% (Foreign Beneficiaries).

Term higher than 10 years: 0% (Individuals, Estates, Foreign Beneficiaries, Institutional Investors).

If the total amount of participation certificates and/or quotas of the fideicomisos and closed FCI, respectively, have not been placed by public offering previously approved by the CNV, the fideicomisos and closed FCI will be subject to Income Tax.
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