The taxpayer is the user or consumer of the digital service. However, if an Argentine resident intermediary mediates in the payment, it must act as withholding agent. If more than one intermediary are involved, the one with the closest business relationship with the digital service provider must act as the withholding agent. If no Argentine payment intermediary is involved, then the recipient of the services must report and pay the VAT through an electronic bank transfer to the Argentine Tax Administration.
Digitalisation is changing the way we understand IEL. New streams of revenue generation resulting from online or digital economic activities remains untapped and unapplied towards steering economic growth. Despite the fact that these new digital models have been met with novel regulatory and tax approaches globally, they are proving problematic in terms of identifying the activity upon which tax should be based. This is because traditional tax rules do not contemplate digital aspects as sources of taxable income. The role of IEL in the digitalisation of the economy therefore, merits consideration, specifically in the area of domestic resource mobilisation as a factor for economic growth especially in Africa.
Unfortunately, the Guide appears to be blind to the way in which conceiving land and tenure rights in the context of global vale chains can multiply the relevant spaces of engagement and challenges the traditional notion of jurisdictional spaces and fragmentation. Luckily, communities, activists and lawyers acting on the ground have come to this realization long ago, and I believe that they will find the best way to use a document that aims to normalize large-scale investments but can also open new interesting spaces for political and legal resistance.