Jorge Lapenta
Business Tax Advisory
Pablo Belaich
Daniel Dasso
Tax and Finance Operate
Pablo Belaich
+54 (11) 4510-2249
Mobile: +54 (911) 6849-2814
Email: jorge.lapenta@ar.ey.com
+54 (11) 4318-1616
Mobile: +54 (911) 5262-6653
Email: pablo.belaich@ar.ey.com
+54 (11) 4318-1694
Mobile: +54 (911) 5114-6999
Email: daniel.dasso@ar.ey.com
+54 (11) 4318-1616
Mobile: +54 (911) 5262-6653
Email: pablo.belaich@ar.ey.com
Tax Technology and Transformation
Santiago Ackermann
Global Compliance and Reporting
Pablo Belaich
Ariel Becher
Gustavo Consoli
Daniel Dasso
Silvia De Vivo
Horacio Lopez
Christian Micieli
Juan Pablo Mizutani
Fernando Montes
Silvana Morano
Diego Riesco
People Advisory Services
Javier Sabin
Indirect Tax
Gustavo Scravaglieri
+54 (11) 4318-1600
Mobile: +54 (911) 5005-7788
Email: santiago.e.ackermann@ar.ey.com
+54 (11) 4318-1616
Mobile: +54 (911) 5262-6653
Email: pablo.belaich@ar.ey.com
+54 (11) 4318-1686
Mobile: +54 (911) 3487-3126
Email: ariel.becher@ar.ey.com
+54 (11) 4318-1705
Mobile: +54 (911) 3487-9491
Email: gustavo.consoli@ar.ey.com
+54 (11) 4318-1694
Mobile: +54 (911) 5114-6999
Email: daniel.dasso@ar.ey.com
+54 (11) 4318-1622
Mobile: +54 (911) 6461-2934
Email: silvia.de-vivo@ar.ey.com
+54 (11) 4318-1609
Mobile: +54 (911) 4024-1032
Email: horacio.lopez@ar.ey.com
+54 (11) 4875-4837
Mobile: +54 (911) 6805-5358
Email: christian.micieli@ar.ey.com
+54 (11) 4318-1657
Mobile: +54 (911) 6804-1678
Email: juanpablo.mizutani@ar.ey.com
+54 (11) 4318-1760
Mobile: +54 (911) 5843-6165
Email: fernando.montes@ar.ey.com
+54 (11) 4318-1798
Mobile: +54 (911) 3773-5470
Email: silvana.morano@ar.ey.com
+54 (11) 4318-1615
Mobile: +54 (911) 6883-9408
Email: diego.riesco@ar.ey.com
+54 (11) 4318-1658
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Email: javier.sabin@ar.ey.com
+54 (11) 4510-2224
Mobile: +54 (911) 3059-0723
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Law
Jorge Garnier
A. At a glance
+54 (11) 4515-2634
Mobile: +54 (911) 3089-6870
Email: jorge.garnier@ar.ey.com
Corporate Income Tax Rate (%) 25 to 35 (a)
Capital Gains Tax Rate (%) 0/15/25 to 35 (b)
Branch Tax Rate (%) 25 to 35 (a)
Withholding Tax (%) Dividends 0/7/35 (c)
15.05/35 (d) Royalties from Patents, Know-how, etc. 21/28/31.5 (d)
Branch Remittance Tax 0/7/35 (c)
Net Operating Losses (Years)
Carryback 0
Carryforward 5
(a) For fiscal years starting from 1 January 2021, the corporate tax is calculated through a progressive scale ranging from 25% to 35%. The scale is updated annually based on the consumer price index. For 2024, annual income from ARS0 to ARS34,703,523.08 is subject to a 25% rate; income from ARS34,703,523.08 to ARS347,035,230.79 is subject to a 30% rate; income exceeding ARS347,035,230.79 is subject to a 35% rate. The amounts are updated annually based on the consumer-price index. An increased rate of 41.5% applies for certain gaming activities.
(b) The 15% rate generally applies to capital gains derived by foreign residents from sales of shares, quotas and other participations in entities. Capital gains derived by foreign residents from listed shares and corporate and government bonds, under certain circumstances, can benefit from an exemption. Argentine corporate residents are subject to the regular corporate tax at rates ranging from 25% to 35%.
(c) A 7% dividend withholding tax rate applies to dividends paid out of profits accrued in fiscal years started from 1 January 2018. Such rate applies to distributions made to resident individuals or foreign investors, while distributions to resident corporate taxpayers are not subject to withholding. A 0% dividend withholding tax rate generally applies to dividends paid out of profits accrued during fiscal years that started before 1 January 2018; however, in these cases, a 35% withholding tax (known as “equalization tax”) is triggered if the distribution exceeds the after-tax accumulated taxable income of the taxpayer.
(d) These are final withholding taxes imposed on nonresidents only. For details concerning the rates, see Section B.
B. Taxes on corporate income and gains
Corporate income tax. Resident companies are taxed on worldwide income. Any profits, including capital gains, are taxable. Companies incorporated in Argentina and branches of foreign companies are considered to be resident companies.
Rates of corporate tax. Corporate tax is payable at a scale ranging from 25% to 35%. For 2024, annual income from ARS0 to ARS34,703,523.08 is subject to a 25% rate; income from ARS34,703,523.08 to ARS347,035,230.79 is subject to a 30% rate; income exceeding ARS347,035,230.79 is subject to a 35% rate. The amounts are updated annually based on the consumer price index. An increased rate of 41.5% applies for certain gaming activities.
Capital gains. Capital gains derived by tax-resident companies are included in taxable income and taxed at the regular corporate tax rate. Capital gains derived by foreign residents from the sale, exchange, barter or disposal of unlisted shares, quotas,
Intangible property may be depreciated only if it has a limited life based on its characteristics. Certain assets, such as goodwill and trade names, may not be depreciated.
Inflationary adjustment. Adjustment for inflation is allowed in accordance with the following rules:
• Inflation adjustment of new acquisitions and investments carried out from 1 January 2018 and onward.
• Application of an integral inflation adjustment mechanism for fiscal years beginning on or after 1 January 2018 if the variation of the Consumer Price Index supplied by the National Institute of Statistics and Censuses is higher than 100% for the 36-month period before the end of the fiscal period.
Relief for losses. Tax losses may be carried forward for five tax periods. Loss carrybacks are not permitted. Certain losses have a specific nature and can only offset the same type of income, such as losses from sales of shares and other types of securities, losses from foreign-source activities and losses from gaming activities.
Except for hedge transactions, losses resulting from the rights contained in derivative instruments or contracts may offset only the net income generated by such rights during the fiscal year in which the losses were incurred or in the following five fiscal years. For this purpose, a transaction or contract involving derivatives is considered a hedge transaction if its purpose is to reduce the impact of future fluctuations in market prices or fees on the results of the primary economic activities of the hedging company.
D. Other significant taxes
The following table summarizes other significant taxes.
Nature of tax
Value-added tax (VAT), on goods delivered and services rendered in Argentina, on services rendered outside Argentina that are used or exploited in Argentina, and on imports
Standard rate 21
Other rates 5/10.5/27
Tax on financial transactions; generally imposed on debits and credits with respect to checking accounts; a portion of the tax may be creditable against other taxes
0.25/0.5/1.2
Various local taxes on gross receipts, real estate and other items Various Tax on purchase of foreign currency (impuesto PAIS)
Nature of tax
Social security taxes (including medical care contributions), on monthly salaries; paid by employer; a portion may be creditable against VAT; the creditable portion varies depending on where the employees render services 24/26.4
Export duties on goods; general rate; other rates apply to certain exports (oil, grains and others) 5 Tax on personal assets; imposed on all legal persons and individuals domiciled abroad holding ownership interests in Argentine companies; tax is calculated based on the equity value of the Argentine company; tax is paid by the Argentine company, but the company may recover the tax paid from the foreign shareholder 0.5
E. Miscellaneous matters
Foreign-exchange controls. From September 2019, the government has reintroduced certain foreign-exchange controls which are periodically reviewed and redefined.
Exporters must repatriate into Argentina the cash derived from exports of goods and services, among other items, within a specified time period.
Funds derived from loans granted from abroad must be settled in the Argentine foreign-exchange market in order to be able to make the repayment using the same mechanism.
Payment of debts to foreign parties can be routed through the foreign-exchange market subject to compliance with certain requirements.
Payments for imports of goods and services can be routed through the foreign-exchange market subject to certain conditions. For goods delivered and services rendered as from 13 December 2023, payments can generally be made according to the following schedule:
• Four installments in the case of goods (30, 60, 90 or 120 days) except for certain specific situations
• After 30 days for non-related party services, and 180 days in the case of related-party services
Payment of dividends is subject to the Central Bank of Argentina’s approval. The Central Bank of Argentina’s prior approval is also needed to access the foreign-exchange market to make investments abroad.
Interest deductibility limitation. Under general principles, transactions between related parties must be made on an arm’s-length basis.
The Argentine income tax law establishes a limit for the deduction of interest arising from financial loans granted by related parties. The limit equals 30% of earnings before interest, taxes, depreciation and amortization (EBITDA) or a certain amount to be determined by the Executive Power (currently ARS1 million), whichever is higher. The limit each year is
(g) The 5% rate applies if the beneficial owner of the dividend is a government of the other contracting state. The 10% rate applies if the beneficial owner of the dividend is a company that controls, directly or indirectly, at least 25% of the voting power of the payer. The 15% rate applies to other cases.
(h) For details concerning these rates, see Section B.