Argentina, Switzerland Sign CAA on MLI Changes Under 2014 DTA, Protocol

The Argentine Treasury June 2 posted online a competent authority agreement (CAA) with Switzerland, signed May 18, modifying the 2014 DTA and protocol under the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The agreement includes measures: 1) allowing adjustments for associated enterprises transactions, if made under similar terms compared to transactions between independent enterprises; 2) adding a rule on Switzerland’s method for eliminating double taxation; 3) allowing mutual agreement procedure (MAP) cases to be presented to either country’s competent authority; and 4) adding a principal purpose test to determine treaty benefits. ...