In brief
On 5 January 2026, the Republic of Argentina published its reservations to the Multilateral BEPS Convention (MLI) with the Organization for Economic Co-operation and Development (OECD) in the Official Bulletin. As a result, the MLI entered into force for Argentina on 1 January 2026 with the published reservations, impacting Argentina’s network of double taxation treaties (DTTs).
In depth
Background and ratification process
The MLI, signed in Paris in 2016 as part of the OECD/G20 BEPS project, is an international agreement that enables the efficient and simultaneous modification of existing DTTs without the need to renegotiate each bilateral treaty individually. This feature is a key innovation of the MLI, allowing for the coordinated and agile amendment of a broad network of treaties. Argentina signed the MLI in 2017 and, following parliamentary approval through Law 27,788, completed the process by formally depositing the instrument with the OECD.
Global scope and relevance
With Argentina’s accession, more than 90 jurisdictions have now ratified, accepted or approved the MLI, resulting in the modification of over 1,600 bilateral double taxation treaties. According to the OECD, approximately 350 additional treaties are expected to be modified as the MLI is ratified by all signatories. The OECD has highlighted that this ratification strengthens the global fight against tax evasion and avoidance, and consolidates Argentina’s commitment to transparency and international tax cooperation.
Main effects and changes
The MLI introduces automatic modifications to DTTs designated as “Covered Tax Agreements” by both parties. The main measures incorporated include the prevention of treaty abuse, mitigation of strategies to avoid the creation of permanent establishments, and neutralization of hybrid mismatch arrangements. In addition, the MLI provides for improvements in dispute resolution mechanisms.
Entry into force
The MLI has been in effect for Argentina since 1 January 2026.
Covered agreements
Upon depositing the instrument of ratification, Argentina notified the OECD of the double taxation treaties that will be covered by the MLI. This list includes treaties concluded with Germany, Australia, Belgium, Bolivia, Brazil, Canada, Chile, Denmark, Spain, Finland, France, Italy, Mexico, Norway, the Netherlands, the United Kingdom, Russia, Sweden, Switzerland and the United Arab Emirates. The effective application of the MLI modifications to each treaty will depend on whether the counterparty has also ratified the instrument and notified the same agreement as covered. The complete and updated list, together with specific reservations and notifications, can be consulted on the official OECD website (see official document here).
Implications for companies
The entry into force of the MLI represents a significant change for multinational companies with operations in Argentina, which should review their structures and international transactions in light of the new provisions.
Reserves made by the Republic of Argentina to the MLI
The reserves are listed in the Annex included in the following link:
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Barbara Roca and Bernardo Trueba, Associates, have contributed to this legal update.
Download the Spanish version of Argentina: Reservations to the Multilateral BEPS Convention.