Football Taxation - Clubs' Perspective: Is There any Withholding Tax Applicable on the Agent Commission Paid Abroad by the Club or the Player?

Argentina

When a payment is made to a foreign beneficiary (in this case, an agent), the first thing to analyze is if the agent’s income derives from an Argentine source or not. If it is from a foreign source (i.e. services provided abroad that do not involve any technical or intellectual consulting), no Income Tax withholding should be applied.

However, if a payment corresponding to income derives from an Argentine source, a withholding will apply as a one-time and final payment, as provided in the Income Tax Law no. 20.628 of 27 December 1973 (Art. 102). This Law presumes the beneficiary’s net income is based on the type of service, and the 35% rate is applied to that net income. In the case of commissions paid to a football player's agent, the presumption of net income would be 31.5% (Art. 102, subsection h of the...

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