Introduction
Seven Latin American countries stated reservations or positions in the recently published 2025 update to the OECD Model Tax Convention. These are of course the four LatAm members of the OECD (Chile, Colombia, Costa Rica, and Mexico) and also the three accession countries to the OECD in the region (Argentina, Brazil, and the one country not featured in the 2017 Model, Peru). This report is the first part of a series – this part focuses on the reservations made by Argentina and Brazil.