In Argentina, tax legislation is often amended when new governments take office, generally in response to financing needs, fiscal efficiency goals, or efforts to modernize in line with international tax policy.

The last major tax reform took place in 2018. Since then, changes have been more specific than structural, such as the creation of the “PAÍS Tax” on foreign currency transactions, the progressive increase of corporate income tax rates, the regulation of export withholdings, and, in 2020, the extraordinary wealth tax.

More recently, the government has enacted a new tax amnesty, allowed for accelerated payment of the wealth tax with fiscal benefits, promoted reforms to the criminal tax regime, amended individual tax return obligations, and updated information exchange thresholds. In 2024, the “Incentive Regime for Large Investments” (RIGI) was introduced, granting projects exceeding USD 200 million a reduced 25% corporate tax rate and 30 years of tax stability. Inspired by OECD standards and comparable to regimes in Uruguay and Chile, it aims to attract capital in a context of high local tax pressure.

As to the legislative process, all tax laws must be approved by the National Congress, with no scope for presidential decrees other than regulatory powers expressly authorized by law. Tax and customs bills originate in the Chamber of Deputies, are reviewed by the Senate, and must then be enacted by the Executive Branch.

In Argentina, the tax system is based on self-assessment: taxpayers must calculate, file, and pay their taxes. Obligations vary according to jurisdiction (federal, provincial, or municipal) and the taxpayer’s category.

At the federal level, there are three main regimes. Monotributo simplifies compliance for small taxpayers through a single monthly payment that covers taxes and social security contributions, with annual recategorization based on income. The General Regime includes, among others, income tax and VAT, requiring monthly and annual filings, accounting records, electronic invoicing, and audited financial statements. This regime is mostly applied by corporations and generally requires professional assistance. Between the two lies the recently proposed Simplified Income Tax Regime, introduced in Congress by the current administration. It establishes an intermediate burden under which returns are pre-drafted by ARCA (the National Tax Authority) based on income and deductions already known to the authority, without requiring information on assets or expenditures, and taxpayers may accept, reject, or adjust them to reflect their economic reality.

At the provincial level, the main tax is Gross Turnover Tax (Impuesto sobre los Ingresos Brutos, IIBB), levied on the revenue of companies and professionals. Some provinces have their own simplified monotributo, but once thresholds are exceeded, taxpayers fall under the general IIBB regime. Where activities span multiple provinces, the Multilateral Agreement applies, allocating the taxable base among them under specific apportionment rules, and requiring both monthly and annual filings. At the municipal level, additional levies include taxes such as Safety and Hygiene, generally payable monthly and annually depending on the activity.

Tax administration has strengthened oversight through digital tools. The Digital VAT Ledger centralizes purchase and sales data for electronic audits, while the electronic credit invoice seeks to expedite payments and improve access to financing for SMEs.

Finally, in 2025, Congress is debating the “Simple VAT” bill, which aims to unify federal and provincial taxes for small taxpayers, reduce informality, and replicate experiences from Brazil and Mexico, with potential impact on business planning.

In Argentina, the principal tax authority is the Federal Tax and Customs Administration (ARCA), responsible for collection, audit, and enforcement in tax, customs, and social security matters. Alongside ARCA, the Ministry of Economy, through the Secretariat of Treasury and the National Tax Directorate, participates in the design and oversight of tax policy.

ARCA has broad powers to review taxpayers’ filings during the statute of limitations period. These audits, generally carried out electronically through the official assessment procedure, aim to verify the accuracy of returns while ensuring taxpayers’ right to be heard. Cases are typically selected based on data cross-checks, third-party information, or annual compliance priorities set by the authority.

During these processes, the authority may request supporting documentation for the filed returns. Failure to respond may result in penalties or even rebuttable presumptions against the taxpayer.

If adjustments arise from an audit, the taxpayer may either accept them and settle the tax with interest and penalties or challenge them through administrative remedies. If the controversy persists, judicial recourse is available before the Tax Court of the Nation or the Federal Courts, depending on the nature of the claim.

In Argentina, tax disputes can be resolved before bodies independent of the tax authority through judicial proceedings. Cases typically begin with an official assessment issued by ARCA, which may be appealed to the Tax Court of the Nation (TFN), a specialized body independent from both ARCA and Customs. TFN allows taxpayers to challenge facts and legal issues without prior payment, and proceedings are now fully electronic.

TFN has broad jurisdiction, although its scope has been narrowed in specific cases by court rulings. It may not declare statutes unconstitutional, except in rare circumstances to apply Supreme Court precedents already established on identical facts.

Decisions of the TFN may be appealed before the Federal Administrative Court of Appeals, which generally requires prior payment of the disputed tax liability and focuses on questions of law, though it may also review factual and evidentiary matters within the limits of the appeal. Cases may ultimately reach the Supreme Court, although its review is exceptional and restricted to matters with potential constitutional implications.

At the provincial level, similar tax courts exist depending on the jurisdiction. Their decisions may be appealed to the local judiciary and, in certain cases, reviewed by the Supreme Court.

There are no official statistics on the duration of tax cases before the TFN or the Federal Administrative Court of Appeals. However, practitioners generally agree that proceedings are lengthy. The Argentine judiciary suffers from structural delays, and Supreme Court statistics for 2024 show an average duration of around 1.6 years per case (with a median just over one year). In practice, a full tax dispute may last several years and, in complex cases, can easily exceed five years, making duration a key factor in a taxpayer’s decision whether to litigate or settle at the administrative stage.

In Argentina, each tax has its own payment schedule. The federal tax authority publishes the official calendar annually, with deadlines determined by the last digits of the taxpayer’s Tax ID (CUIT).

Main deadlines include:

• Personal Income Tax and Personal Assets Tax (individuals): annual filing and payment. For 2024, the due date was in June 2025, followed by five bimonthly advance payments.
• Corporate Income Tax: annual filing based on the company’s fiscal year-end, with nine monthly advance payments during the following year.
• Value Added Tax (VAT): monthly filing and payment, due in the middle of the following month.
• Social security contributions: monthly filing and payment by employers, due in the middle of the following month.

As for payment of disputed amounts, two main rules apply. If the taxpayer appeals before the Tax Court of the Nation, payment is suspended, and no amount is due until an adverse ruling is issued. If the case is further appealed before the Federal Court of Appeals, the appeal has only non-suspensive effect: the liability must be paid or secured within 30 days of notification, failing which ARCA may enforce collection. In social security matters, the law also requires a prior deposit as a condition to appeal.

Debt regularization plans often allow taxpayers to include disputed amounts if they agree to settle, a mechanism repeatedly used in recent years. This has reduced the number of significant judicial precedents, as many cases end at the administrative stage.

In Argentina, a tax secrecy regime applies, requiring the Federal Tax and Customs Administration (ARCA) and its officials to maintain the confidentiality of taxpayer information, including tax returns, financial statements, reports, and data obtained through audits. As a rule, such information may not be disclosed, and any breach of secrecy may give rise to criminal liability.

There are exceptions where information may be shared:

• When certain notifications must be made by public notices in newspapers due to the taxpayer’s domicile being unknown.
• Exchanges with international, federal, provincial, or municipal tax authorities for enforcement within their jurisdictions, pursuant to applicable treaties and regulations.
• With third parties engaged by ARCA to carry out administrative or data-processing tasks, subject to the same duty of confidentiality.
• Regarding financial statements and accounting reports of public companies listed on the stock exchange.
• Public agencies vested with specific powers: ANSES (social security and welfare), the Office of the Attorney General, the Judiciary, the Financial Intelligence Unit, the Central Bank, the Securities Commission, the Insurance Superintendency, INAES (cooperatives and mutuals regulator), and public registries of companies and beneficial ownership.

Argentina is a signatory to the OECD’s Common Reporting Standard (CRS) and participates in the automatic exchange of financial information with more than 100 jurisdictions. Local financial institutions must report to the Federal Tax and Customs Administration (ARCA), which then transmits the data to foreign tax administrations under the Multilateral Competent Authority Agreement (MCAA). The CRS covers account balances and other financial data, significantly expanding transparency. The official list of participating jurisdictions is available on the OECD website: https://www.oecd.org/content/dam/oecd/en/topics/policy-issues/tax-transparency-and-international-co-operation/crs-mcaa-signatories.pdf

Argentina also complies with FATCA through an intergovernmental agreement with the United States. The annual exchange takes place in September and, unlike the CRS, is limited to accounts in Argentina held by U.S. citizens and U.S. tax residents, without reporting balances.

Regarding beneficial ownership, Argentina currently maintains parallel regimes. On the tax side, ARCA requires reporting under its own framework (most recently through General Resolution 4697 and subsequent amendments), while the General Inspectorate of Justice (IGJ) imposes a separate regime under corporate law. The thresholds and criteria differ: the IGJ generally applies a 10% ownership or control test, whereas ARCA has broader requirements without a fixed percentage, except in specific cases such as listed companies.

This coexistence of regimes reflects a lack of full unification between the tax authority and the corporate registry, resulting in overlapping obligations and, in some cases, inconsistent criteria. While both frameworks pursue the same objectives (preventing tax evasion and money laundering) companies must still comply with both sets of rules, which increase administrative burdens and legal uncertainty.

In the Argentine Income Tax system, residence is decisive in determining whether an entity is taxed on worldwide income or only on Argentine-source income. The Income Tax Law distinguishes between opaque entities (with tax personality) and transparent entities (without tax personality or subject to the international tax transparency regime).

1. Opaque entities: residence by incorporation or location

Entities incorporated in Argentina are considered residents, including corporations (S.A.), limited liability companies (S.R.L.), partnerships, associations, foundations, cooperatives, mutuals, trusts, and mutual funds. Sole proprietorships and permanent establishments of foreign entities located in Argentina are also deemed residents. The rule is straightforward: residence is defined by the place of incorporation or location. Unlike other systems, there is no “place of effective management” test. Consequently, if the entity is incorporated in Argentina or has a permanent establishment in the country, it is taxed on worldwide income, while non-residents are only taxed on Argentine-source income. In practice, activities or management centers in Argentina of non-Argentine corporations may be treated as permanent establishments (PEs).

2. Transparent entities: direct allocation to partners

Certain entities lack tax personality in their jurisdiction of origin. In such cases, they are not taxpayers themselves, and income is directly attributed to the resident partners or beneficiaries in Argentina, as if earned personally. The allocation follows the rules of the Income Tax Law for each category of income, with the possibility of crediting similar foreign taxes paid. A foreign entity is only recognized as an independent taxpayer if it is subject to income tax in its jurisdiction of incorporation. Conversely, if the vehicle is treated as “pass-through” in its home country (such as transparent LLCs in the United States), Argentina regards it as lacking tax personality, and income is attributed directly to the Argentine partner, subject to certain conditions.

Argentina applies a comprehensive transfer pricing regime aligned with the OECD Guidelines.

Transfer pricing:
All transactions with related parties must comply with the arm’s length principle, allocating income according to functions, assets, and risks. The law recognizes the five traditional OECD methods:

• Comparable uncontrolled price method
• Resale price method
• Cost plus method
• Transactional net margin method
• Profit split method

In addition, Argentine legislation includes a “sixth method” for commodity exports involving international intermediaries, defined as goods with public quotations on international markets (metals, hydrocarbons, and agricultural products). In these cases, the taxpayer must justify the intermediary’s economic substance and demonstrate that its remuneration is consistent with market conditions. Otherwise, the Federal Tax and Customs Administration (ARCA) adjusts the taxable base to the market value at the time of shipment.

ARCA oversight:
ARCA closely monitors cross-border transactions within multinational groups, focusing on limited-risk distribution structures and sensitive sectors such as agribusiness, pharmaceuticals, and automotive. Common disputes involve the selection of comparables, adjustments for macroeconomic factors (inflation, devaluation, business cycles), and determination of profit margins. Unlike the OECD standard, the burden of proof lies with the local entity.

Advance pricing arrangements:
The law introduced the “Joint Determination of International Transaction Prices” (DCPOI), equivalent to an APA, which is still pending regulation. This mechanism is intended to allow taxpayers to agree with ARCA on applicable methodologies or margins, with binding effect.

In general terms, and subject to certain conditions, Argentina has CFC rules under which:

• If an Argentine resident controls a foreign trust, the trust’s income is attributed to the Argentine resident.
• If an Argentine resident holds an interest in a foreign transparent (disregarded) entity, that entity’s income is attributed to the Argentine resident.
• If an Argentine resident holds an interest in a foreign non-transparent entity that derives 50% or more of its income from passive sources, its profits are attributed to the Argentine resident, provided certain conditions are met.

In addition, profits derived from foreign branches are generally treated as foreign-source income of the local company, with the possibility of claiming foreign tax credits.

For transfer pricing rules and safe harbours, see question 9.

Argentina has a thin capitalization regime that limits the deduction of interest and foreign exchange losses on debts with related parties, whether domestic or foreign. The deduction is subject to the following parameters:

• Limit: 30% of tax EBITDA (net income before interest, depreciation, and amortization).
• Excess: non-deductible interest may be carried forward for up to five fiscal years.

Main exceptions:

• Not applicable to financial entities, financial trusts, or companies whose main business is leasing with purchase option, provided financial activity is secondary.
• Not applicable where debt with related parties does not exceed the group’s level of debt with independent creditors.
• Where the foreign beneficiary has been subject to Argentine withholding tax on interest, the limitation applies only to foreign exchange losses.

Argentina applies a general anti-avoidance rule known as the “economic reality” principle, which allows the tax authorities to prioritize substance over form where legal structures do not reflect the true economic intent.

At the international level, Argentina adhered to the OECD/G20 BEPS Multilateral Instrument (MLI), which incorporates the principal purpose test (PPT) and limitation on benefits (LOB) provisions into bilateral treaties, aimed at preventing treaty shopping practices.

Application of the economic reality principle in case law:

• Molinos Río de la Plata (Supreme Court, 2016): rejected a Chilean holding company lacking economic substance, confirming that no treaty may be invoked abusively.
• Praxair (Tax Court 2019 – Court of Appeals 2021 – Attorney General’s opinion 2025): involved the use of Spanish ETVE companies to access treaty benefits.
  • The Tax Court upheld the adjustment due to lack of substance.
  • The Court of Appeals, citing Molinos, concluded there was treaty abuse.
  • The Attorney General argued that the Spain–Argentina treaty did not contain anti-abuse clauses, and extending the economic reality principle to treaty application would violate pacta sunt servanda. It also emphasized the burden of proof on the tax authority. The case is pending before the Supreme Court.

Other relevant Supreme Court precedents include Fiat Concord SA, Red Hotelera Iberoamericana, and Petrolera Pérez Companc, which have consolidated the economic reality principle as a GAAR of jurisprudential rather than statutory origin.

Argentina does not currently have a stand-alone digital services tax (DST), but it applies a multi-layered system that in practice imposes a significant burden on foreign providers.

• Income Tax: The 2017 tax reform (Law 27,430) originally proposed a separate regime to tax foreign digital services, presuming that 50% of the price paid for services used in Argentina was deemed Argentine-source income, which would have triggered a 17.5% withholding for non-residents. This provision was removed from the final law, and therefore no specific income tax regime is in force today.
• VAT on digital services: Since 2018, digital services consumed in Argentina have been subject to 21% VAT, even when the user is an end-consumer. The tax is collected through perceptions made by credit card companies. The place of use is presumed based on objective indicators such as IP address, SIM card, billing address, or the issuing bank of the payment card, with no possibility of rebuttal.
• Impuesto PAIS: Since 2019, cross-border digital purchases have been subject to an 8% surcharge, in addition to the 21% VAT, resulting in a combined indirect tax burden of 29% on digital consumption under federal rules.
• Provincial Gross Turnover Tax: Since 2018, several provinces have introduced regimes to capture services from foreign digital providers, also collected through perceptions made by credit card companies. Buenos Aires introduced the concept of “significant digital presence,” later followed by Córdoba in 2019, and similar rules now apply in Mendoza, La Pampa, Salta, San Juan, Tucumán, Neuquén, Chaco, Santa Fe, San Luis, and Jujuy. These schemes have been challenged in court on grounds of violating the constitutional principle of territoriality and Federal Tax Revenue Sharing Law (Law 23,548).
• International perspective: Argentina closely follows progress under the OECD/G20 BEPS framework. If Pillar One is successfully implemented, it may be incorporated and adapted into the domestic framework. Otherwise, the country may move forward with unilateral or regional measures, in addition to those already in place.

Argentina maintains a cooperative stance with the OECD/G20 BEPS project and has progressively incorporated several of its recommendations into its domestic and treaty framework. In 2025, Congress completed the internal approval of the Multilateral Instrument (MLI) to modify tax treaties in line with BEPS standards; its entry into force still requires notification and deposit with the OECD, which is underway.

With respect to Pillar Two (15% global minimum tax), Argentina has not yet enacted full GloBE rules (IIR, UTPR, or a QDMTT) in its domestic law. However, Law 27,742 (the “Ley de Bases”) and its implementing Decree 749/2024 established the Large Investment Incentive Regime (RIGI), which includes an express compatibility clause with the minimum taxation standard: incentives under the RIGI will not apply if they would trigger a “reallocation of income to foreign tax authorities” through the application of Pillar Two rules (IIR/UTPR or equivalent). In this way, Argentina explicitly acknowledges the international standard and seeks to ensure that its incentives are not neutralized by external rules.

With respect to Pillar One (Amount A / Amount B), Argentina has not implemented these measures domestically. Internationally, the Multilateral Convention to implement Amount A (MLC) has not yet been finalized or opened for signature, and the technical process is ongoing. Accordingly, Argentina continues to monitor developments but has not incorporated these rules into its law. Amount B was consolidated by the OECD in 2025 as transfer pricing guidance for baseline distributors, but it has not yet been formally adopted in Argentina.

In addition, the authorities have reinforced cooperation, tax transparency, and alignment with OECD standards in the context of Argentina’s ongoing institutional engagement and continue to closely follow developments under Pillars One and Two for potential future implementation.

Argentina has incorporated several OECD/G20 BEPS recommendations, aligning its domestic legislation with those standards.

Actions implemented:

• Action 3 (controlled foreign companies): Law 27,430 attributes passive income earned by low- or no-tax foreign entities to Argentine residents.
• Action 4 (interest deductions): a cap of 30% of EBITDA or ARS 1,000,000 per year applies to related-party financial debt; non-deductible excess interest may be carried forward for five fiscal years.
• Action 5 (harmful tax practices and transparency): Argentina participates in the peer review process of the Inclusive Framework.
• Action 6 (treaty abuse): in May 2025, Argentina ratified the MLI (Law 27,788), which incorporates the principal purpose test (PPT) and limitation on benefits (LOB) clauses into its existing treaties.
• Actions 8–10 (transfer pricing): enhanced requirements for local files and master files, requiring more detailed information on cross-border transactions and aligning comparability criteria.
• Action 13 (country-by-country reporting): implemented by General Resolution 4130-E, requiring multinational groups with global revenues exceeding EUR 750 million to submit CbC reports.

Actions in progress:

• Action 1 (digital economy): although Argentina has no standalone digital services tax (DST), B2C digital services are taxed through VAT, the Impuesto PAIS, and provincial turnover taxes.
• Actions 8–10: continuing adjustments to documentation and enforcement requirements, with a focus on multinational group transactions.

The Argentine tax system covers all categories contemplated in the OECD Model. Current treatment is summarized as follows:

• Business profits: resident corporations are subject to corporate income tax at progressive rates of 25% to 35% on net income. Permanent establishments of foreign companies are taxed at the same rates plus a 7% withholding on dividends.
• Employment income and pensions: resident individuals are taxed on salaries and pensions at progressive rates from 5% to 35%, adjusted semiannually after deductions for dependents and certain expenses. Employers contribute 24% or 26.4% to social security, while employees contribute 17% on remuneration up to a monthly cap.
• VAT and other indirect taxes: value added tax applies at a general rate of 21%, with a reduced rate of 10.5% for certain goods and an increased rate of 27% for telecommunications and energy services. In addition, excise taxes apply to items such as tobacco, beverages, and insurance, and a tax on bank debits and credits applies at 0.6%–1.2%.
• Savings income and royalties: interest and royalties received by residents are included in income tax. Payments to non-residents are subject to final withholding at 35% on deemed taxable income.
• Income from land: rental income and sales of real estate are subject to income tax; non-habitual transactions are taxed at a flat rate of 15%. Provinces levy property taxes and municipalities levy contributions, generally ranging from 0.5% to 2% of assessed value.
• Capital gains: The sale of shares, bonds, equity interests, and cryptocurrencies by resident individuals is subject to a 15% tax, with certain exemptions. For corporations, capital gains are consolidated with ordinary income and taxed under the progressive corporate income tax scale of 25%–35%.
• Net worth tax: individuals are subject to the Personal Assets Tax at progressive rates from 0.5% to 1.25% on local and foreign assets.
• Provincial Gross Turnover tax and stamp duty: provinces levy gross turnover tax on business and professional activities at rates typically between 3% and 7%, depending on the activity. They also apply stamp duty on documented acts and contracts, generally averaging 1% of the transaction value.

In sum, the Argentine system covers all OECD Model categories, but with a complex structure that combines national, provincial, and municipal taxes, and varying rates depending on the taxpayer’s type and residence, alongside customs duties on imports.

In Argentina, the taxable income of resident legal entities is determined on the basis of a tax balance sheet, which starts from the accounting balance sheet and is adjusted according to the Income Tax Law. Key adjustments include:

• foreign exchange differences,
• specific tax depreciation rules,
• limitations on deductions for debts with related parties or entities in non-cooperative jurisdictions, and
• the inflation adjustment mechanism, which in 2025 continues to apply in fiscal years where cumulative inflation exceeds statutory thresholds.

In general, corporations are taxed on an accrual basis. However, certain deductions (for example, payments to related parties or to entities in non-cooperative jurisdictions) are only allowed on a cash basis, upon effective payment.

In Argentina, common business vehicles such as corporations are treated as taxpayers for income tax purposes and are therefore opaque: they are taxed on their own income. However, certain regulated structures may be treated as transparent under specific conditions.

At the domestic level, examples include:

• Irregular companies (sociedad irregular)
• Informal partnerships (sociedad de hecho)
• Administrative trusts, considered transparent when the settlors are also the beneficiaries and no foreign beneficiaries are involved
• Publicly offered financial trusts and closed-end mutual funds, which are considered transparent if they have a public offering and invest in local assets

These vehicles are frequently used in sectors such as real estate, venture capital, and collective investment, where they provide tax efficiency and greater flexibility compared to regular corporations, with taxation falling directly on the investors according to their own tax situation.

At the international level, certain foreign structures may also be treated as transparent, in which case Argentina applies its controlled foreign company (CFC) rules (see answers to questions 8.2 and 10).

See answer to question 8 for national taxes.

Argentina has several promotional regimes aimed at strategic sectors and investment incentives. The main ones include:

• Renewable Energy (Laws 26,190 and 27,191): accelerated depreciation, early VAT refund on goods and works, and exemption from import duties on equipment.
• Forestry Promotion (Law 25,080): accelerated depreciation, VAT refund, tax stability, and valuation of reserves at market value.
• Mining Regime (Law 24,196): provides 30 years of tax stability, accelerated amortization, benefits in internal and customs taxes, and VAT refunds under certain conditions.
• Tierra del Fuego Special Customs Area (Law 19,640): broad exemption from national taxes, including CIT and VAT, together with extensive customs benefits.
• Large Investment Incentive Regime (RIGI): designed for projects in agriculture, infrastructure, forestry, mining, hydrocarbons, energy, and technology. It offers a reduced CIT rate of 25%, accelerated depreciation, unlimited loss carryforwards, a 0% dividend withholding after three years, VAT refunds through tax certificates, tariff exemptions, relief from foreign exchange repatriation requirements, and long-term tax, customs, and foreign exchange stability backed by international protection.
• SME Regime (Law 27,264): allows micro and small businesses to defer VAT payments for 90 days and credit 100% of the tax on bank debits and credits against CIT.
• Knowledge Economy Promotion Regime (Law 27,506): covers innovative sectors such as software, audiovisual, biotechnology, nanotechnology, aerospace, nuclear, and Industry 4.0. Benefits include reductions in CIT (60% for micro and small companies, 40% for medium, 20% for large), exemption from VAT withholdings on exports, foreign tax credit recognition, and conversion of up to 70% of employer social security contributions into tax credits.
• Free Trade Zones (Law 24,331): allow operations exempt from import and export duties, benefits on basic services, and flexibility for industrial and commercial activities aimed at exports. An example is the Zapala Free Trade Zone (Neuquén), where cryptocurrency mining projects use surplus natural gas under a preferential scheme.

Argentina does not have a regime comparable to European “patent boxes” granting specific benefits for income derived from intellectual property. Instead, such matters are addressed within the general income tax framework, which applies deemed net income rules to outbound payments for intangibles or technology transfers.

Under the Income Tax Law, part of the payment is presumed to be Argentine-source net income. The presumptions vary by type of contract:

• Technical assistance, engineering, or consultancy services: 21% of the payment, provided the services are not available in Argentina, the contract complies with Technology Transfer Law 22,426, is registered with the National Institute of Industrial Property (INPI), and the services are effectively rendered.
• Assignment or licensing of patents and other intangibles: 25% of the payment, subject to registration with INPI and compliance with applicable regulations.
• Copyrights: 12.25% of the payment, provided the work is registered with the National Copyright Office and certain conditions are met.

This regime seeks to encourage the transfer of technology and the legitimate use of intellectual property under registered and certified contracts, thereby promoting local access to foreign know-how and ensuring oversight and transparency in such transactions.

Argentina does not have a fiscal consolidation regime. Each company is treated as a separate taxpayer for income tax purposes, and tax grouping is not allowed. As a result, losses cannot be transferred or offset among companies within the same group.

The system follows a separate-entity approach: each company may only carry forward its own tax losses against its own future taxable income, subject to the statutory five-year limitation period.

The only partial exception is found in the thin capitalization rules (see question 11), which allow the debt-to-equity ratio to be calculated based on the consolidated position of the wider economic group to which the local entity belongs.

In Argentina, cross-border payments are subject to withholding tax at the following rates, unless a double taxation treaty applies, in which case the rate may be reduced. The effective withholding rate depends on the nature of the payment:

• Dividends and profit distributions: 7% on distributions made by local companies to non-resident shareholders.
• Royalties and license fees:
  • Registered technology transfer agreements with the National Institute of Industrial Property (INPI), involving technology not available locally: effective withholding of 21% or 28%, depending on the contract.
  • Unregistered contracts or technology available in Argentina: 31.5%.
• Interest:
  • Cooperative financial creditors or loans used to import depreciable goods: 15.05%.
  • Other creditors or non-cooperative jurisdictions: 35%.
• Services and professional fees: where no specific presumption applies, 90% of the payment is deemed taxable income, resulting in an effective withholding of 31.5%.

All Argentine-source income paid to non-residents is withheld as a single and final tax, with the taxable base determined through statutory presumptions. If the withholding cannot be made, the local payer is legally required to remit the tax.

Argentina does not have a general environmental tax applicable to businesses. There is no structured “green tax” system, and environmental protection is usually financed through general service fees. However, certain specific levies are regulated:

• Carbon dioxide tax: established under Law 23,966, it applies to the carbon content of certain fuels. The rate is set in fixed amounts in pesos per liter or kilogram, adjusted quarterly. This tax seeks to discourage the consumption of carbon-intensive fuels and to align with international commitments under the Kyoto Protocol (Law 25,438) and the Paris Agreement (Law 27,270).
• Hazardous Waste Environmental Levy: provided under Law 24,051, it requires generators, transporters, and operators to register with the national registry and pay an annual fee. The amount is determined according to the hazardousness and volume of the waste, with a cap of 1% of the presumed profit from the activity. It functions as an environmental policy tool rather than a payment for services.
• Provincial and municipal charges: some jurisdictions impose levies for water use, effluent control, or other environmental services. These vary by province or municipality and are not part of a uniform nationwide regime.

The Income Tax Law distinguishes between dividends of domestic and foreign source, and taxation depends on the type of recipient:

• Dividends distributed by Argentine companies
  • Since the 2018 reform, profits distributed by local companies are subject to a 7% withholding tax, levied by the distributing company.
    This withholding is final where the recipient is either a resident individual or a non-resident entity.
  • If dividends are received by another resident company, they are not included in its taxable base, and no withholding applies. Taxation is deferred until the company distributes profits to its own shareholders.
• Dividends distributed by non-resident companies
  • For Argentine residents, these are considered foreign-source income and are taxed under the general progressive income tax scale (up to 35%).
  • As Argentina applies worldwide taxation, residents may credit against their liability any equivalent foreign income taxes paid.

Argentina offers significant investment opportunities in renewable energy, mining, oil and gas, agriculture, and technology, while also presenting material challenges for international groups considering relocation.

Advantages

• Tax treaty network: Argentina has double taxation treaties with Germany, Australia, Austria, Belgium, Bolivia, Brazil, Canada, Chile, China, Denmark, United Arab Emirates, Spain, Finland, France, Italy, Japan, Luxembourg, Mexico, Norway, the Netherlands, Qatar, the United Kingdom, Russia, Sweden, Switzerland, and Turkey. These treaties facilitate international tax planning and reduce withholding taxes on dividends, interest, and royalties.
• Strategic position: Privileged access to Mercosur and Andean markets, along with abundant energy, agricultural, and mineral resources that support large-scale projects.
• Tax incentives: The Large Investment Incentive Regime (RIGI) sets the corporate tax rate at 25%, allows accelerated depreciation, grants fiscal and exchange stability for 30 years, and eases access to foreign exchange markets, making it attractive for infrastructure, mining, energy, and technology projects.
• Free trade zones and customs regimes: Locations such as La Plata, Tierra del Fuego, and Zapala offer VAT and import duty exemptions, combined with provincial and municipal benefits. Zapala stands out as an emerging hub for cryptocurrency mining, leveraging surplus natural gas.
• Recent reforms: In 2025, foreign exchange restrictions (“cepo cambiario”) were lifted for individuals, official market access was granted for the repatriation of profits from fiscal years beginning in 2025 and for external debt repayments under certain conditions, monthly inflation fell below 2%, and digitalization of the tax system advanced, strengthening legal certainty. The corporate foreign exchange restrictions remain, though under review for possible further liberalization.

Challenges

• High tax burden: The maximum corporate tax rate reaches 35% (versus a regional average of 28%), the general VAT rate is 21% (above the 16% regional average), and personal income tax is progressive up to 35%. Employer social security contributions and labor costs, close to 40%, increase overall costs.
• Regulatory complexity: The overlap of national, provincial, and municipal taxes, along with frequent legal changes, generates uncertainty and high compliance costs.
• Macroeconomic risks: Despite lower inflation, the economy remains exposed to devaluation and currency volatility.
• Political instability: Market-oriented reforms face domestic resistance and may be reversed in future government cycles.

In summary, Argentina combines competitive advantages such as international treaties, promotional regimes, strategic resources, and recent reforms with a high tax burden. However, incentive regimes are proving attractive to foreign investors in mining and energy, with a national impact. Macroeconomic risks and regulatory instability persist. Argentina may serve as an attractive platform for regional expansion, provided it is accompanied by rigorous tax planning, careful management of political and economic risks, and a case-by-case assessment of tax and customs benefits.