Argentina – Tax Treaty Protocol with France Enters into Force on 22 October 2026

WHY THIS MATTERS

The confirmed entry-into-force and application dates provide employers, payroll teams, global mobility program managers, and internationally mobile employees with a timetable for applying the amended Argentina-France treaty provisions.

Organizations with Argentina-France mobility arrangements extending into 2027 may need to revisit treaty-based withholding positions, payroll processes, assignment cost projections, tax equalization calculations, and supporting documentation before the relevant provisions begin to apply.

KPMG INSIGHTS

The official confirmation provides greater certainty regarding when organizations may need to begin applying the amended treaty provisions. The distinction between withholding taxes and other taxes on income and capital remains relevant because the Protocol describes their application by reference to payments and fiscal years, respectively.

Organizations and entities with affected cross-border arrangements might wish to consider:

• Employers could identify Argentina-France assignments and cross-border payment arrangements that will remain active into 2027.
• Payroll teams could review treaty-based withholding assumptions for payments made from 1 January 2027.
• Global mobility teams could revisit assignment cost projections, tax equalization calculations, and shadow payroll processes.
• Employers could review whether treaty-relief forms or supporting documentation will need to be updated.
• Employers could communicate the timing of the amendments to affected employees before the provisions begin to apply.

If assignees and/or their programme managers have any questions or concerns about the scope of the update, its application and potential impacts, and appropriate next steps, they should consult with their qualified professional or a member of the GMS team with KPMG in Argentina (see the Contacts section).