ABSTRACT

This paper will present an analysis of the mechanisms used by the commodity export sectors in order to avoid and evade income tax, shifting the profits from Argentina to offshore jurisdictions. In particular, it will address the use of elusive structures, such as shell companies, in combination with the exploitation of tax treaties in order to avoid the payment of taxes on dividends (treaty shopping) and other practices that erode the tax base, such as thin capitalization, services, and royalty payments to evade income tax. In addition, undervaluation of commodity exports and overvaluation of commodity imports through intermediary companies located abroad, in order to shift profits offshore, will also be analyzed. Finally, the relationship between the mechanisms described above and capital flight from Argentina will also be addressed.