On 30 April 2024, the Argentine Central Bank (BCRA) issued Communication "A" 7999, which allows the subscription of Bonds for the Reconstruction for a Free Argentina (BOPREAL) to pay profits and dividends to nonresident shareholders. (For background, see EY Global Tax Alert, Argentina to issue "Bonds for the Reconstruction for a Free Argentina" dated 10 January 2024.)
This subscription would be for up to the equivalent in local currency of the total profits and dividends pending payment, based on the distribution documented in the shareholders' meeting minutes.
The bank must verify compliance with certain requirements and reflect the transaction through an "exchange sales ticket" in the name of the client, stating the nominal value of the BOPREAL awarded in foreign currency.
The Communication also allows companies acquiring the BOPREAL under this regulation to access the foreign exchange market for the payment of profits and dividends through an exchange and/or arbitrage with the funds deposited in a local account and originated in the collection of principal and interest of the bonds.
Finally, the regulations enable subscription of BOPREAL by nonresidents for up to the equivalent in local currency of the total profits and dividends collected in Argentine Pesos in Argentina since 1 September 2019 that have not been remitted abroad, adjusted by the latest Consumer Price Index available as of the subscription date.
Contact Information
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For additional information concerning this Alert, please contact:Pistrelli, Henry Martin & Asociados S.R.L., Buenos Aires
Ernst & Young LLP (United States), Latin American Business Center, New York
Ernst & Young LLP (United Kingdom), Latin American Business Center, London
Ernst & Young Tax Co., Latin American Business Center, Japan & Asia Pacific
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Published by NTD’s Tax Technical Knowledge Services group; Carolyn Wright, legal editor
For a full listing of contacts and email addresses, please click on the Tax News Update: Global Edition (GTNU) version of this Alert.
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