Argentina Cross-Border Tax Guide 2026

Overview — Source vs Worldwide Taxation

Argentina employs a mixed tax system: residents are taxed on their worldwide income (renta mundial), while non-residents are taxed only on Argentine-source income at flat withholding rates. The tax system is primarily source-based for non-residents and worldwide-based for residents. Since the 2018 tax reform (Law 27,430), Argentina has gradually shifted toward a more territorial approach for certain types of income (e.g., foreign-source dividends, capital gains on foreign assets), but the worldwide principle remains the general rule for residents. Tax residents are subject to the Impuesto a las Ganancias (IIT) at progressive rates of 5-35% and the Impuesto sobre los Bienes Personales (wealth tax) on global assets above the threshold.

Tax Residency — The 183-Day Rule

An individual is considered a tax resident of Argentina if they meet any of the following conditions during the tax year (calendar year):

• Physical presence: Present in Argentina for more than 183 days in the calendar year (continuously or intermittently)
• Permanent residence permit: Hold a permanent residence permit (residencia permanente) granted by Argentine immigration authorities (Dirección Nacional de Migraciones), regardless of physical presence
• Main center of vital interests: Argentina is deemed the center of the individual's economic and personal interests (family, business, assets)
• Argentine citizenship: Argentine citizens are presumed to be residents unless they prove they have established tax residency in another country (with a tax residence certificate)

Non-residents are taxed only on Argentine-source income at flat rates: 15% on services, 31.5% on dividends (reduced under DTAs), 15% on interest, and 35% on capital gains on Argentine assets. The 183-day count includes partial days and considers the individual's location at midnight.

Double Tax Agreement (DTA) Network

Argentina has signed more than 20 Double Tax Agreements (DTAs), largely based on the OECD Model Convention with some UN Model influences. As of 2026, Argentina has DTAs in force with:

Active DTAs: Australia, Austria, Belgium, Bolivia, Brazil, Canada, Chile, Denmark, Finland, France, Germany, Italy, Japan, Liechtenstein, Luxembourg, Mexico, Netherlands, Norway, Russia, South Africa, Spain, Sweden, Switzerland, United Arab Emirates, United Kingdom, Uruguay, Venezuela.

Key DTA features:

• Permanent establishment threshold: Generally 6 months (construction/building sites) or 183 days (services), more favorable than the OECD standard of 12 months
• Dividend withholding: Typically 10-15% (reduced from the domestic 31.5% rate)
• Interest withholding: Typically 3-15% (reduced from the domestic 15.5% rate)
• Royalty withholding: Typically 10-15% (reduced from the domestic 31.5% rate)
• Capital gains: Generally taxed in the country of residence of the seller, with exceptions for real estate and shares deriving value from local real estate

Argentina also has a Tax Information Exchange Agreement (TIEA) with the United States (not a full DTA) and has signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI).

Foreign Tax Credit (FTC)

Argentina provides a foreign tax credit (crédito por impuesto pagado en el exterior) to resident taxpayers who pay foreign income tax on foreign-source income that is also subject to Argentine tax. The FTC features:

• Per-country limitation: The credit is calculated separately for each foreign country (not a global pooling system)
• Source category limitation: The credit is limited to the Argentine tax attributable to the foreign-source income per source category
• Carry-forward: Unused foreign tax credits can be carried forward for 5 years
• No carry-back
• Treaty override: DTAs may provide more favorable FTC treatment than domestic law

The FTC cannot exceed the Argentine tax that would be payable on the same income. The credit is claimed on the annual Ganancias tax return (Form F.711). The taxpayer must provide evidence of foreign tax paid (certificate from the foreign tax authority or audited tax return).

Controlled Foreign Corporation (CFC) Rules

Argentina's CFC rules (Transparencia Fiscal Internacional), introduced in the 2018 tax reform (Law 27,430) and modified by subsequent legislation, attribute passive income of foreign entities to Argentine resident controlling persons:

• Threshold: Argentine resident(s) directly or indirectly control a foreign entity (corporation, trust, foundation, or other structure)
• Low-tax jurisdiction: The foreign entity is resident in a jurisdiction with a tax rate less than 75% of the applicable Argentine rate (i.e., effective tax rate < ~26.25% for corporate income, or listed on the Argentine blacklist of "naciones no cooperantes" or "jurisdicciones no cooperantes")
• Passive income: The foreign entity generates more than 50% passive income (dividends, interest, royalties, rents, capital gains) that is not effectively connected to an active trade or business
• Attribution: The passive income is attributed proportionally to Argentine controlling residents and taxed at the applicable IIT rate (5-35%), with a foreign tax credit for taxes paid at the entity level

The CFC rules apply to both individuals and corporations. Argentine residents must report their participation in foreign entities on the annual tax return (Ganancias and Bienes Personales) and may need to file the CFC disclosure form if thresholds are met.

Transfer Pricing Rules

Argentina has comprehensive transfer pricing rules based on the OECD Transfer Pricing Guidelines. Key features:

• Arm's length principle: Related-party transactions must be priced at arm's length
• Documentation: Local file, master file, and country-by-country (CbC) reporting for groups with consolidated revenue > ARS 10 billion (~EUR 100 million)
• Methods: Traditional transactional methods (CUP, resale price, cost plus) and transactional profit methods (TNMM, profit split) are accepted, with a preference for traditional methods
• Penalties: Significant penalties (up to 300% of the tax adjustment) for non-compliance or incorrect pricing
• Specific rules: Commodity transactions, intangibles, intra-group services, and financial transactions have specific documentation requirements

Exit Tax — Expatriation

Argentina imposes an exit tax on individuals who cease to be tax residents. Under the expatriation rules (introduced in Law 27,430):

• Deemed disposal: When an individual gives up Argentine tax residency, they are deemed to have sold all their worldwide assets at fair market value
• Tax rate: Capital gains on the deemed disposal are taxed at 15% (reduced from the general 35% for certain asset categories)
• Exemption: The first ARS 10 million (~USD 28,000) of deemed gains are exempt
• Deferral: The exit tax can be deferred if the individual provides a guarantee (e.g., bond or bank guarantee) and files an annual return reporting the deferred gain
• Re-entry: If the individual re-establishes Argentine residency within 5 years, the exit tax is reversed and the deferral (if used) terminates

The exit tax applies to both Argentine citizens and foreign nationals who have been tax residents of Argentina for at least 5 of the last 10 years. To formally cease tax residency, the individual must file a sworn statement with AFIP/ARCA and provide evidence of tax residency in another country.

FAQs

What happens if I have a DTA country and a non-DTA country income?

Income from DTA countries is taxed according to the treaty provisions, which may limit Argentina's taxing rights. Income from non-DTA countries is taxed under domestic law, with a foreign tax credit available. You must report all worldwide income on your Argentine tax return and then claim the treaty benefits (if applicable) or foreign tax credit. The per-country limitation for FTCs applies separately to each country.

How does Argentina's currency control affect cross-border transactions?

Argentina maintains strict foreign exchange controls (cepo cambiario) that affect cross-border tax payments and profit repatriation. As of 2026, residents must obtain Central Bank approval for most outward foreign currency transfers. Dividends and profit remittances abroad are subject to: (1) the 31.5% withholding tax on dividends, (2) a 30% "impuesto país" (PAIS tax) on certain foreign currency purchases, and (3) Central Bank approval with a waiting period of up to 120 days. The PAIS tax rate was reduced from 35% to 30% in 2024 and may be further reduced.

Are foreign pensions taxable in Argentina?

Yes, foreign pension income is generally taxable in Argentina as worldwide income for residents. However, if the pension is from a DTA country, the treaty usually provides that the pension is taxable only in the country of residence (Argentina) unless the pension is from government service (which may be taxable only in the paying country). The foreign tax credit can offset double taxation. Foreign pension income is reported in the Ganancias tax return and taxed at progressive rates of 5-35%.

What is the impuesto país (PAIS tax)?

The Impuesto Para una Argentina Inclusiva y Solidaria (PAIS tax) is a 30% tax on purchases of foreign currency for certain purposes (savings, travel, imports of goods and services). It applies to: credit card purchases abroad, foreign currency for travel, and certain cross-border payments. The tax is deductible for income tax purposes for businesses but not for individuals. As of 2026, the PAIS tax rate is 30% (reduced from the original 35% in 2024) and may be phased out over time.

Does Argentina have a wealth tax on offshore assets?

Yes, the Impuesto sobre los Bienes Personales (wealth tax) applies to worldwide assets of Argentine residents, including offshore assets. The rate is 0.25-1.5% on assets exceeding the exemption threshold (approximately ARS 25 million in 2026). Foreign real estate, bank accounts, investments, and other assets held abroad must be declared and are subject to the tax. The foreign tax credit for wealth taxes is generally not available because Bienes Personales is not an income tax.

Disclaimer

This guide provides general information about cross-border taxation involving Argentina for the 2026 tax year. Tax laws, treaty provisions, currency controls, and CFC rules are subject to frequent changes. The information presented reflects published AFIP/ARCA, Ministry of Economy, and DTA provisions and may not reflect individual circumstances. Always consult with a qualified international tax advisor or Argentine contador público for advice specific to your cross-border situation. InvestmentKit does not provide tax or legal advice.