Argentina Guía de Impuesto a las Ganancias Corporativo 2026

Corporate Income Tax Rate Schedule

Argentina reduced its corporate income tax rate through a multi-year schedule under Law 27,630:

• 2020 and earlier: 35%
• 2021–2023: 35% (retained rate; full reduction was deferred)
• 2024: 30% (first step of the reduction)
• 2025–2026: 25% (current rate for fiscal years beginning on or after January 1, 2025)
• 2027 onwards: 20% (planned further reduction)

The rate applies to net taxable profit (ganancia neta sujeta a impuesto), determined according to the Income Tax Law and regulations. Note that fiscal years may be different from calendar years; the rate applicable is the one in effect at the start of the fiscal year.

Dividend Withholding Tax (WHT)

• Rate: 7% on the gross amount of dividends or profit distributions paid to individuals (resident or non-resident) and foreign beneficiaries.
• Base: The dividend is paid out of after-tax profits (the company has already paid 25% corporate income tax, so the effective combined rate is approximately 1 - (1 - 0.25) × (1 - 0.07) = 30.25%).
• Exemptions: Dividends paid to other Argentine corporations are generally exempt, as are profit distributions between related companies under certain conditions.
• Non-residents: Subject to the same 7% WHT rate on dividends, unless a tax treaty provides a reduced rate.

Controlled Foreign Corporation (CFC) Rules

• Argentina has CFC rules (transparencia fiscal internacional) that attribute passive income of foreign-controlled entities to the Argentine controlling shareholder when the foreign entity is located in a low-tax jurisdiction (nación de baja tributación or "tax haven").
• Passive income includes interest, dividends, royalties, rental income, capital gains, and certain other investment income.
• The Argentine shareholder must include the CFC's passive income in their own taxable income on an accrual basis, regardless of actual distribution.
• Active business income of foreign subsidiaries is generally not attributed until distributed.
• Argentina maintains a list of low-tax jurisdictions (those with effective tax rates below 20%) and countries with privileged tax regimes.

Branch Profits and Permanent Establishments

• Foreign companies operating through a branch or permanent establishment (PE) in Argentina are subject to the standard 25% corporate rate on profits attributable to the Argentine PE.
• Branch profits remitted to the head office are treated similarly to dividends and subject to a 7% WHT.
• The repatriation of branch profits is subject to the same WHT as dividends distributed by Argentine subsidiaries.

Tax Depreciation and Amortization

• Fixed assets: Depreciated using the straight-line method over their estimated useful lives (e.g., buildings 50 years, machinery 10 years, vehicles 5 years, computers 3 years).
• Intangible assets: Amortized over their useful life or the legal protection period, whichever is shorter.
• Inflation adjustment: Argentina applies a tax inflation adjustment (ajuste por inflación impositivo) when cumulative inflation exceeds 100% over a three-year period. This adjusts the tax basis of fixed assets, inventories, and equity for inflation, which can significantly impact the tax depreciation calculation.

Tax Loss Carryforward

• Operating tax losses can be carried forward for up to 5 fiscal years.
• Losses must be adjusted for inflation (using the tax inflation adjustment mechanism) before carryforward.
• No carryback of losses is permitted.
• The loss carryforward is reduced by the tax inflation adjustment on the loss amount.

FAQs

What is the effective combined tax rate on corporate profits distributed as dividends?

For 2026, the combined rate is approximately 30.25%: 25% at the corporate level, then 7% WHT on the remaining 75%, giving an effective rate of 1 - (0.75 × 0.93) = 30.25%.

Are there transfer pricing rules in Argentina?

Yes, Argentina has comprehensive transfer pricing rules aligned with OECD guidelines. Transactions with related parties must be at arm's length. Documentation requirements include local file, master file, and country-by-country reporting for groups exceeding certain thresholds.

What is the inflation tax adjustment?

When cumulative inflation over 36 months exceeds 100%, companies must apply a tax inflation adjustment (ajuste por inflación impositivo). This adjusts assets, liabilities, and equity for inflation, recognizing inflationary gains or losses in taxable income.

Aviso Legal

Este guia fornece informações gerais sobre o imposto corporativo na Argentina para 2026. Leis e alíquotas podem mudar. Sempre consulte um contador ou a AFIP para orientação específica. InvestmentKit não fornece aconselhamento tributário.