Argentina Tax Regime

Argentina taxes corporations on worldwide income under a progressive corporate income tax scale of 25%, 30% and 35%, with bracket thresholds indexed annually for inflation. A second layer of tax applies on distributions: dividends and branch profit remittances bear a 7% withholding. The federal system coexists with significant provincial taxation — most notably the turnover tax on gross revenues — and with a financial transactions tax on bank debits and credits, which together materially affect effective burdens. Since the 2024 'Ley Bases' reform package the direction of policy has been toward stabilisation and investment promotion, headlined by the RIGI large-investment incentive regime, alongside the replacement of the federal tax agency AFIP with a new authority, ARCA. Persistent inflation makes the mandatory integral tax inflation adjustment a central feature of income determination.

1.1 Sources

Primary legislation includes the Income Tax Law (Ley de Impuesto a las Ganancias, consolidated text), the VAT Law (Ley de IVA), the Personal Assets Tax Law (Bienes Personales), the Tax Procedure Law (Ley 11.683) and the Ley Bases investment-incentive framework (Ley 27.742), together with implementing decrees and ARCA general resolutions.

1.2 Recent developments

The Ley Bases package enacted in mid-2024 created the RIGI incentive regime for large investments (a stabilised 25% corporate rate and customs, VAT and foreign-exchange benefits for qualifying projects), launched a broad tax amnesty and asset-regularisation programme, and legislated a multi-year phase-down of the personal assets (wealth) tax. The PAIS tax on foreign-currency transactions lapsed at the end of December 2024. The tax agency AFIP was replaced by ARCA (Agencia de Recaudación y Control Aduanero) in late 2024. Corporate bracket thresholds, personal deductions and the personal rate scale continue to be indexed for inflation; for fiscal years beginning in 2026 the corporate bands run to ARS 133.5 million (25%) and ARS 1,335.1 million (30%), with 35% above. Argentina has not enacted Pillar Two legislation.

Headline statutory corporate income tax rate for a resident company. Where sub-national (state, provincial, cantonal or municipal) corporate taxes apply, the combined rate reported by the OECD is shown. Projected 2026–2028 rates carry the current rate forward unless a change is already enacted or officially scheduled. As-of 2026.

Top marginal statutory personal income tax rate on employment income for a resident individual. Where sub-national (state, provincial, cantonal or municipal) income taxes are a standard part of the system, the combined top rate is shown. Projected 2026–2028 rates carry the current rate forward unless a change is already enacted or officially scheduled. As-of 2026.

2.1 Rates and residence

Companies incorporated in Argentina — principally the SA (corporation), SRL (limited liability company) and SAS (simplified corporation) — are resident and taxable on worldwide income, with an ordinary credit for foreign income taxes on foreign-source income. Non-resident entities are taxed only on Argentine-source income, generally by way of final withholding. The corporate income tax is progressive: for fiscal years beginning on or after 1 January 2026 (indexed), taxable income up to ARS 133,514,185.74 is taxed at 25%; income above that and up to ARS 1,335,141,857.38 bears ARS 33,378,546.43 plus 30% on the excess; and income above ARS 1,335,141,857.38 bears ARS 393,866,847.93 plus 35% on the excess. Because the thresholds are indexed annually, most mid-sized and large businesses face a marginal rate of 30–35%.

Provincial jurisdictions levy turnover tax on gross revenues (typically 1–5% depending on activity and province), and municipalities add safety-and-hygiene levies; these are deductible for corporate income tax but are not creditable, so they must be modelled as an additional cost of doing business.

2.2 Dividends and participation

Dividends received by an Argentine company from another Argentine company are not included in the recipient's taxable base, avoiding economic double taxation within domestic chains. Dividends and branch profit remittances paid to resident individuals or to non-residents bear a final 7% withholding on profits generated in fiscal years starting on or after 1 January 2018. The former 35% 'equalisation tax' was abolished for post-2017 profits but remains applicable to distributions made out of pre-2018 accumulated earnings that exceeded tax earnings at the relevant year-end. There is no participation-exemption system for foreign shareholdings: foreign dividends are taxable with a foreign tax credit, subject to the CFC rules described below.

2.3 Income determination and inflation adjustment

Taxable income is determined on an accrual basis from statutory accounts adjusted for tax rules. Expenses necessary to obtain, maintain and preserve taxable income are deductible if fair and reasonable; non-deductible items include the corporate income tax itself, undocumented payments (subject to a penalty tax) and certain payments to low-tax or non-cooperative jurisdictions unless paid and matched with substance. Depreciation is generally straight-line over useful life (buildings 2% per year). The integral tax inflation adjustment applies when cumulative inflation thresholds are met — as they consistently have been — requiring monetary assets and liabilities and equity positions to be restated, and fixed-asset cost bases and depreciation are indexed for acquisitions from 2018 onward. Inventory is valued under specific replacement-cost style rules.

2.4 Interest limitation

Deduction of interest on financial loans with related parties is limited to 30% of tax EBITDA or an annually updated absolute threshold, whichever is higher, with a three-year carryforward of denied interest and a five-year carryforward of unused capacity. Exceptions apply to financial institutions and where the lender has already been taxed in Argentina on the interest. Interest paid abroad is additionally subject to withholding (section 4), and transfer pricing rules govern the arm's-length rate.

2.5 Losses

Net operating losses may be carried forward five years; there is no carryback. Ring-fenced baskets apply: foreign-source losses offset only foreign-source income, and losses from derivatives (other than hedges) and from sales of shares offset only income of the same character. Loss carryforwards are restated for inflation, which preserves their real value in a high-inflation environment.

2.6 Group taxation

Argentina has no fiscal consolidation or group relief: each company is assessed separately, and losses cannot be surrendered between group members. Intra-group transactions between local entities must nonetheless be conducted on market terms, and reorganisations within an economic group (mergers, spin-offs, transfers within a group) can qualify as tax-free where statutory continuity-of-interest, activity-maintenance and notification requirements are met, with carryover of tax attributes.

2.7 Controlled foreign companies

Argentine residents are taxed currently on the passive income of controlled foreign entities that lack substance or are located in low- or no-tax or non-cooperative jurisdictions, under transparency rules that attribute the income to the Argentine controller in the year it accrues. Trusts and foundations in which the settlor retains control are likewise looked through. Statutory lists of non-cooperative jurisdictions and a definition of low-tax jurisdictions (effective rate below 60% of the minimum Argentine corporate rate) drive both the CFC rules and pricing presumptions.

2.8 Transfer pricing

Transactions with foreign related parties and with parties in low-tax or non-cooperative jurisdictions must be at arm's length, tested under methods aligned with international standards, with the 'best method' rule and mandatory annual transfer pricing studies. Documentation is three-tiered — local file, master file and country-by-country reporting for groups above the international EUR 750 million-equivalent threshold — with electronic filing of informative returns. Commodity exports through international intermediaries face specific registration and pricing-date rules designed to counter triangulation. Advance pricing agreements are available under a determinative joint-agreement procedure, though practice remains limited.

2.9 Incentives

The flagship regime is RIGI (Régimen de Incentivo para Grandes Inversiones): projects investing at least USD 200 million in qualifying sectors (energy, mining, infrastructure, technology, steel, forestry, oil and gas, among others) obtain a stabilised 25% corporate rate, accelerated depreciation, unrestricted loss carryforwards, early VAT recovery, reduced dividend withholding after seven years, customs and foreign-exchange benefits, and 30-year regulatory stability. The knowledge-economy regime grants software, IT and other qualifying service exporters a reduction of the corporate tax liability (60% for micro and small companies, 40% medium, 20% large) plus a social-security credit. Sector regimes cover mining (fiscal stability for 30 years), renewable energy and Tierra del Fuego.

2.10 Pillar Two

Argentina has not enacted the OECD Pillar Two global minimum tax and, as of June 2026, has no published implementation bill. Argentine members of in-scope multinational groups may nonetheless be affected by income inclusion or undertaxed profits rules applied by parent jurisdictions, and RIGI-incentivised entities in particular should model potential top-up exposure abroad. The headline rates (25–35%) mean most non-incentivised Argentine operations comfortably exceed the 15% minimum.

2.11 Branch income and reorganisations

A branch (permanent establishment) of a foreign company is taxed on Argentine-source attributable profits at the same progressive scale as companies and must keep separate accounting. Profit remittances to the head office bear the same 7% tax as dividends. Tax-free reorganisations — mergers, demergers and intra-group transfers — require that the businesses be ongoing, that activity continue for two years, that shareholders retain the required interest, and timely notification; attributes including loss carryforwards transfer subject to seniority conditions on the participations.

3.1 Residence and rates

Resident individuals are taxed on worldwide income; non-residents on Argentine-source income via final withholding. Argentine nationals are residents unless they lose residence by acquiring foreign residence or by twelve months' continuous absence; foreign nationals become residents after twelve months of presence, while expatriates working in Argentina for up to five years under employment assignments retain non-resident-style treatment on foreign income. Employment, business and most other income is taxed under a progressive scale from 5% to 35%, with brackets and personal allowances indexed for inflation (semi-annually for employees). Employees are subject to monthly wage withholding that is generally final absent other income. A simplified 'monotributo' regime combines income tax, VAT and social contributions in a single fixed monthly payment for small taxpayers below turnover thresholds.

3.2 Capital income and gains

Dividends from Argentine companies bear the final 7% tax. Interest on Argentine bank deposits in pesos and income from publicly offered local securities benefit from broad exemptions for resident individuals following the unwinding of the earlier schedular tax on financial income. Gains on the sale of unlisted Argentine shares and quotas are taxed at 15% on the net gain (non-residents may opt for 13.5% of gross proceeds); gains on Argentine listed shares traded on authorised markets are exempt for residents. Gains on real estate acquired from 2018 are taxed at 15% with an indexed cost basis; the seller's home is exempt. Foreign-source financial income of residents (interest, foreign dividends, foreign funds) is taxed on a net basis at the progressive scale or specific rates, with foreign tax credits.

3.3 Wealth tax, social security and payroll

The personal assets tax (Bienes Personales) applies to worldwide assets of resident individuals above an indexed non-taxable minimum, with an additional allowance for the family home. Under the 2024 reform the progressive rates are being phased down year by year, converging toward a single low rate of 0.25% from 2027, and compliant taxpayers who prepaid under the special regime locked in stabilised treatment. Employees contribute 17% of capped salary to social security (pension, health and social services); employers contribute roughly 24–27% of uncapped payroll depending on their category, with a portion creditable against VAT in certain regions. Self-employed individuals pay the 'autónomos' scheme or monotributo.

3.4 Inbound and outbound individuals

There is no federal inheritance or gift tax (the province of Buenos Aires levies its own), and provincial stamp duties apply to onerous instruments. Inbound assignees should plan around the five-year expatriate window, the personal assets tax exposure that begins with residence, and the treatment of employer-provided benefits, most of which are taxable. Loss of residence triggers an obligation to appoint a local representative and settle final-withholding treatment; there is no general exit tax on unrealised gains, but the personal assets tax applies through the year of departure and non-residents remain within its scope for Argentine-situs assets via a substitute taxpayer.

Payments to non-residents are subject to final withholding on presumed net income at the general 35% rate (or the 7% dividend rate), producing well-known effective rates: 7% on dividends and branch remittances; 15.05% on interest on qualifying loans from banks in cooperative jurisdictions or on registered import financing, and 35% on other interest; 21% on technology-transfer services registered under the technology-transfer law and 28% on unregistrable technical assistance, with 31.5% for royalties under registered licence agreements and 35% of presumed income for unregistered arrangements; and 12.25–17.5% on lease and freight categories. Argentina's treaty network of roughly two dozen conventions — including with most major European economies, Brazil, Canada, Chile, Mexico and, more recently, Japan, Türkiye, Luxembourg and China — typically caps dividends at 10–15%, interest at 12% and royalties at 3–15% depending on category. Treaty relief requires residence certification on prescribed forms and is subject to anti-abuse scrutiny.

Because withholding operates on statutory presumed-profit percentages of the gross payment, grossing-up clauses in cross-border contracts materially raise the effective cost and should be negotiated with the withholding mechanics in view. Registration of technology-transfer and licence agreements with the competent authority before payment is a precondition for the reduced rates, and payments to non-cooperative jurisdictions face the least favourable presumptions.

5.1 General anti-abuse and pricing presumptions

The Tax Procedure Law codifies the 'economic reality' principle, allowing ARCA to recharacterise structures whose legal form does not match their economic substance. Transactions with low-tax and non-cooperative jurisdictions are presumed not to be at arm's length and trigger transfer pricing documentation regardless of relatedness, deduction timing restrictions (payment-basis deductibility), and harsher withholding presumptions. Thin-capitalisation policing operates through the 30% EBITDA interest barrier and arm's-length testing of rates, and undocumented outflows attract the 35% penalty tax on top of non-deductibility.

5.2 Treaties, information exchange and disclosure

Argentina has signed the OECD multilateral instrument, embedding the principal-purpose test into covered treaties as ratification progresses, and participates in the Convention on Mutual Administrative Assistance, CRS automatic exchange of financial account information and country-by-country exchange, alongside a FATCA intergovernmental agreement with the United States. Beneficial-ownership reporting to the tax authority is mandatory for local entities and structures. Foreign-exchange regulations, although progressively liberalised since 2024, remain a practical overlay on cross-border payments: profits, royalties and intercompany financial flows must be sequenced against prevailing central-bank access rules, and RIGI vehicles enjoy preferential access.

6.1 VAT

VAT applies at a standard 21% rate on sales of goods, services and imports, with a 10.5% reduced rate for items including certain foodstuffs, capital goods, interest on qualifying bank loans and passenger transport, and an increased 27% rate for utilities (energy, gas, water, telecoms) supplied to registered businesses. Exports are zero-rated with recovery of input VAT through a refund procedure; digital services supplied from abroad to Argentine customers are taxed via reverse charge or card-issuer collection. Returns and payments are monthly. VAT withholding and 'perception' (collection-at-source) regimes operated by large purchasers, customs and banks accelerate collection and routinely generate balances that must be managed through offset or refund requests.

6.2 Turnover tax, financial transactions and other taxes

Each province and the City of Buenos Aires levies turnover tax on gross revenues at activity-dependent rates, commonly 1–5% (higher for intermediation), coordinated across jurisdictions by the multilateral agreement (Convenio Multilateral) with its allocation formula; a dense web of provincial withholding and perception regimes applies. The tax on bank debits and credits applies at 0.6% on each debit and each credit (1.2% combined round trip), with 33% creditable against income tax; check-clearing avoidance schemes are penalised. Provincial stamp taxes of around 1–4% hit onerous contracts including real estate transfers and leases. Excise taxes apply to tobacco, alcohol, luxury goods, insurance and electronics; export duties persist for key commodities at reduced rates; and import duties follow the Mercosur common external tariff. There is no federal net wealth tax on companies, but companies act as substitute taxpayers for the personal assets tax on their resident-individual and foreign shareholders at 0.5% of proportional equity value.

7.1 Filing, assessment and audit

The tax year for companies is the financial year; for individuals, the calendar year. Corporate returns are filed electronically with ARCA generally in the fifth month after year-end (May for calendar-year companies), with tax paid on filing after crediting advances: ten advance payments are due monthly from the sixth month of the current year, the first at 25% of the prior-year tax and nine further instalments of 8.33% each. Individuals file annually around June with their own advance schedule. Assessments become final after a five-year statute of limitations for registered taxpayers (ten years for unregistered), suspended or interrupted by specified acts. Audits are risk-scored and data-driven — e-invoicing is universal, and ARCA cross-checks VAT, customs, payroll and financial-information flows; large taxpayers sit within a dedicated directorate.

7.2 Appeals, penalties and regularisation

A deficiency assessment (determinación de oficio) can be challenged within the agency, then before the National Tax Court (Tribunal Fiscal de la Nación) — which suspends collection — or the federal judiciary, with further appeal to the federal chambers and ultimately the Supreme Court. Interest accrues on late payments at resolution-set monthly rates that track the inflationary environment; omission penalties run to 100% of the tax (up to 200% in aggravated transfer pricing cases) and fraud penalties from two to six times the tax, with criminal exposure above statutory thresholds under the penal tax law. Binding consultations are available on future transactions. Recurrent instalment and regularisation programmes — most recently under the 2024 package — allow taxpayers to settle debts with reduced interest and penalty waivers, and the mutual agreement procedure is available under treaties.

Deadlines fall on staggered dates fixed each year by general resolution according to the final digit of the taxpayer's CUIT identification number, so exact days vary by taxpayer; the pattern above is the stable framework. Late payment triggers compensatory interest immediately, and most withholding regimes impose near-immediate remittance, making treasury calendars unusually dense compared with single-payment jurisdictions.

9.1 Entity choice

The SA (sociedad anónima) and SRL (sociedad de responsabilidad limitada) are the standard vehicles; both are opaque for tax and taxed identically at the corporate scale. The SRL is administratively lighter and is the usual choice for wholly owned subsidiaries; the SA suits larger or regulated businesses; the SAS offers fast digital incorporation where available. Branches of foreign companies are taxed like companies on attributable profits plus the 7% remittance tax, so the total burden broadly matches a subsidiary, but branches expose head-office capital and face registration and reporting of their own. Partnerships and trusts are generally taxed at entity level except pure-transparency cases. Foreign shareholders must register and appoint local representatives.

9.2 Structuring and incentives

Large projects should be screened for RIGI eligibility first: the stabilised 25% rate, VAT and customs relief, foreign-exchange priority and 30-year stability materially change project economics. Service exporters should evaluate the knowledge-economy regime's rate reductions and social-security credits. Financing structures must clear the 30% EBITDA related-party interest barrier, the arm's-length rate test and the 15.05%/35% withholding split, all layered with foreign-exchange access rules; equity funding indexed through the inflation adjustment is often more efficient than it first appears. Distribution planning is comparatively simple — a flat 7% on dividends — but pre-2018 earnings pools must be tracked for residual equalisation-tax exposure. Provincial turnover tax and the debits-and-credits tax should be built into pricing, and location decisions can leverage provincial incentive agreements.

9.3 Worked effective-rate illustration

An Argentine SRL has taxable income of ARS 2,000,000,000 for its 2026 fiscal year after all adjustments, including the inflation adjustment. Corporate tax under the indexed scale is ARS 393,866,847.93 on the first ARS 1,335,141,857.38, plus 35% on the excess of ARS 664,858,142.62, i.e. ARS 232,700,349.92 — a total of ARS 626,567,197.85, an average effective rate of 626,567,197.85 / 2,000,000,000 = 31.3%. If the full after-tax profit of ARS 1,373,432,802.15 is distributed, dividend withholding of 7% takes a further ARS 96,140,296.15, bringing the combined burden on distributed profits to ARS 722,707,494.00, or 36.1% of pre-tax income — before provincial turnover tax and the bank debits-and-credits tax, which typically add several points of effective burden depending on margin structure.

9.4 Compliance

Expect universal e-invoicing, monthly VAT, payroll and provincial filings, annual corporate and transfer pricing filings, beneficial-ownership and foreign-shareholder informative regimes, and substitute-taxpayer wealth-tax filings for shareholders. Withholding-agent obligations are pervasive: businesses of any scale act as agents for income tax, VAT and turnover tax, with strict-liability penalties. Inflation accounting affects both statutory and tax numbers, so tax provisioning requires indexed calculations. Given rate and rule volatility, a standing monitoring process for federal reform bills, provincial rate laws and ARCA resolutions is essential, and material positions benefit from binding consultations.