Argentina's System Argentina recently introduced a residence-based tax system, and its law in this area is evolving. Argentine law generally provides that resident individuals are subject to tax on their worldwide income. But there is no general concept of residence for individuals contained in the governing income tax law. The definition of individual residence contained in the rules for personal allowances provides that an individual will be deemed a resident of Argentina if he or she is present in Argentina for at least six months during the tax year. Thus, a six-month assignment may subject an employee to Argentine tax on worldwide income.
Residents also are subject to wealth tax on worldwide property holdings.
Withholding tax obligations will apply to both resident and nonresident employees of an Argentine employer. If the transferred employee remains employed by a company that is not a resident in Argentina, the employee is liable for income tax under the withholding rules, but no resident employer serves as a withholding agent, and there is no provision for individual tax returns by such a non-resident employee. In situations where the employee is transferred or seconded to an Argentine-affiliate employer, the Argentine employer must comply with withholding requirements, even if the employee is nonresident. Canadian Tax Jurisdiction Canadian tax jurisdictional principles are similar to Argentina's. Canadian residents are taxed on their worldwide income, and residence is established after 183 days.