Through Opinion of the Federal Tax Administration (“FTA”) No. 4/2016, published in the Official Gazette on August 18, 2016, the FTA sets forth that the bonuses for termination of labor relationships by mutual agreement will not consider subject to Income Tax.

Such criterion was set by the Argentine Supreme Court of Justice (“ASCJ”) in the case “Negri”^[1], in which the ASCJ pointed out that the bonuses for termination of the labor relationships were excluded from the Income Tax, since the termination of the employment relationship implies the disappearance of the employee’s source of income.

[1] ASCJ, “Negri, Fernando v. FTAI” 07/15/2014.

[1] CSJN, “Negri, Fernando c/AFIP-DGI” 15/07/2014.

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Thus, through the abovementioned opinion, the FTA ends the discussion regarding this matter, in harmony with the doctrine set by the ASCJ.

Finally, it must be highlighted that Opinion No. 4/2016 complements Opinions No. 3/2012 and 4/2012, issued by the FTA under the cases “Cuevas”[1] and “Lorenzo”[2]. Through those opinions, the FTA ruled in favor of the non-taxability of payments made in compensation for stability and union resources and dismissal due to pregnancy.

[1] ASCJ “Cuevas, Luis Miguel v. FTAI”, 11/30/2010.

[2] ASCJ, “De Lorenzo Amalia Beatriz v. FTA”, 06/17/2009.

Through Opinion of the Federal Tax Administration (“FTA”) No. 4/2016, published in the Official Gazette on August 18, 2016, the FTA sets forth that the bonuses for termination of labor relationships by mutual agreement will not consider subject to Income Tax.

Such criterion was set by the Argentine Supreme Court of Justice (“ASCJ”) in the case “Negri”^[1], in which the ASCJ pointed out that the bonuses for termination of the labor relationships were excluded from the Income Tax, since the termination of the employment relationship implies the disappearance of the employee’s source of income.

[1] ASCJ, “Negri, Fernando v. FTAI” 07/15/2014.

[1] CSJN, “Negri, Fernando c/AFIP-DGI” 15/07/2014.

I am text block. Click edit button to change this text. Lorem ipsum dolor sit amet, consectetur adipiscing elit. Ut elit tellus, luctus nec ullamcorper mattis, pulvinar dapibus leo.

Thus, through the abovementioned opinion, the FTA ends the discussion regarding this matter, in harmony with the doctrine set by the ASCJ.

Finally, it must be highlighted that Opinion No. 4/2016 complements Opinions No. 3/2012 and 4/2012, issued by the FTA under the cases “Cuevas”[1] and “Lorenzo”[2]. Through those opinions, the FTA ruled in favor of the non-taxability of payments made in compensation for stability and union resources and dismissal due to pregnancy.

[1] ASCJ “Cuevas, Luis Miguel v. FTAI”, 11/30/2010.

[2] ASCJ, “De Lorenzo Amalia Beatriz v. FTA”, 06/17/2009.

Through Opinion of the Federal Tax Administration (“FTA”) No. 4/2016, published in the Official Gazette on August 18, 2016, the FTA sets forth that the bonuses for termination of labor relationships by mutual agreement will not consider subject to Income Tax.

Such criterion was set by the Argentine Supreme Court of Justice (“ASCJ”) in the case “Negri”^[1], in which the ASCJ pointed out that the bonuses for termination of the labor relationships were excluded from the Income Tax, since the termination of the employment relationship implies the disappearance of the employee’s source of income.

[1] ASCJ, “Negri, Fernando v. FTAI” 07/15/2014.

[1] CSJN, “Negri, Fernando c/AFIP-DGI” 15/07/2014.

I am text block. Click edit button to change this text. Lorem ipsum dolor sit amet, consectetur adipiscing elit. Ut elit tellus, luctus nec ullamcorper mattis, pulvinar dapibus leo.

Thus, through the abovementioned opinion, the FTA ends the discussion regarding this matter, in harmony with the doctrine set by the ASCJ.

Finally, it must be highlighted that Opinion No. 4/2016 complements Opinions No. 3/2012 and 4/2012, issued by the FTA under the cases “Cuevas”[1] and “Lorenzo”[2]. Through those opinions, the FTA ruled in favor of the non-taxability of payments made in compensation for stability and union resources and dismissal due to pregnancy.

[1] ASCJ “Cuevas, Luis Miguel v. FTAI”, 11/30/2010.

[2] ASCJ, “De Lorenzo Amalia Beatriz v. FTA”, 06/17/2009.