JUNE 24, 2022

Publication of the list of jurisdictions with low or nil taxation (JLNT).


Tax Law Department Report | Publication of the list of jurisdictions with low or nil taxation (JLNT)

Dear Sir or Madam,

On June 22nd, 2022, the Federal Tax Authority (AFIP) published on its website the updated list of jurisdictions that have a general corporate tax regime of less than 15% and that qualify as low or nil taxation jurisdictions, according to the provisions of art. 20 of the Income Tax Law (2019 text) and the first paragraph of art. 25 of the Regulatory Decree (2019 text).

Jurisdictions with low or nil taxation (JLNT) correspond to those countries, domains, jurisdictions, territories, associated states, or special tax regimes that establish a maximum taxation of business income of less than 15%. For the purposes of determining the aforementioned level of taxation, the total tax rate must be considered, which taxes business income in each jurisdiction, regardless of the levels of government that have established them.

Among the most important aspects, it is established that the list is not exhaustive and that it was made for guidance, without including special tax regimes, being subject to the due diligence of the taxpayer the analysis of the treatment of the income generated in each jurisdiction. It is delegated to the taxpayer to determine if any of the special regimes in force in the evaluated jurisdiction should be applied. If the corporate income is not taxed or is taxed at an effective rate of less than 15%, the respective regime would classify as a JLNT.

“Special tax regime” shall mean any specific regulation or scheme that appears from the general corporate income tax regime in force in that country and that results in an effective rate lower than that established in the general regime.

Click here to access the complete list.

Please, do not hesitate to contact us should you require any further information.


Santiago L. Montezanti