International Tax Review is part of the Delinian Group, Delinian Limited, 8 Bouverie Street, London, EC4Y 8AX, Registered in England & Wales, Company number 00954730
Copyright © Delinian Limited and its affiliated companies 2023

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Argentina enacts tax amnesty provisions and other significant tax changes

The Argentine government enacted Law 27,260 (the Law) with special incentives for Argentine taxpayers to report previously unreported assets.


Andrés Edelstein

Ignacio Rodríguez

The Law also includes modifications to various tax provisions. The primary objective of the Law is to raise tax revenue to reduce the government's outstanding pension debt.

The amnesty intends to encourage Argentine businesses and individuals to unreported foreign and domestic assets. To benefit from the amnesty, taxpayers must report such assets by March 31 2017.

Assets reported may be subject to a reduced tax rate ranging from 5% to 15%, depending on the type of asset, the asset's total value, and whether the reporting is done during 2016 or in the first three months of 2017. A 0% rate may apply if the reported assets are invested in specific Argentine sovereign bonds or local mutual funds that focus on local development projects such as renewable energies or infrastructure.

The Law also allows taxpayers to settle any unpaid tax liability (including social security contributions and import/export duties), offering a partial exemption on accrued interest and no penalties. It also allows outstanding tax to be paid using an instalment plan.

The Law also contains other significant tax reforms, including:

  • Repealing the 10% withholding tax on dividend distributions introduced in 2013. However, the so-called equalisation tax – a 35% withholding tax on amounts distributed in excess of accumulated tax earnings – remains in effect;

  • Reducing wealth tax rates. The 0.5% rate levied on net equity held by foreign shareholders or Argentine individuals will be reduced to 0.25%. Taxpayers who can demonstrate full compliance with tax duties during fiscal years 2014 and 2015 are able to enjoy a temporary exemption from this tax for years 2016 to 2018; and

  • Repealing the minimum notional income tax of 1% on taxable assets. The tax, which applies only if the amount exceeds the company's income tax liability, will no longer apply from January 1 2019.

In addition, the Law also creates a Parliamentary Commission for analysing and evaluating the tax reform proposals to be sent by the Executive Branch within the next year. The planned changes intend to reduce the overall tax burden and make the tax structure simpler and more progressive.

Multinationals enterprises with operations or investments in Argentina should consider how these new measures may affect them. In particular, elimination of the 10% withholding tax on dividends may affect repatriation decisions and related modelling exercises. Also, they should monitor how the envisioned tax reform proposals expected to be sent to the Congress impact their local operations.

Andrés Edelstein ( and Ignacio Rodríguez (, Buenos Aires


Tel: +54 11 4850 4651


more across site & bottom lb ros

More from across our site

With the M&A market booming, ITR has partnered with correspondents from firms around the globe to provide a guide to the deal structures being employed and how tax authorities are responding.
Xing Hu, partner at Hui Ye Law Firm in Shanghai, looks at the implications of the US Uyghur Forced Labor Protection Act for TP comparability analysis of China.
Karl Berlin talks to Josh White about meeting the Fair Tax standard, the changing burden of country-by-country reporting, and how windfall taxes may hit renewable energy.
Sandy Markwick, head of the Tax Director Network (TDN) at Winmark, looks at the challenges of global mobility for tax management.
Taxpayers should look beyond the headline criteria of the simplification regime to ensure that their arrangements meet the arm’s-length standard, say Alejandro Ces and Mark Seddon of the EY New Zealand transfer pricing team.
In a recent webinar hosted by law firms Greenberg Traurig and Clayton Utz, officials at the IRS and ATO outlined their visions for 2023.
The Asia-Pacific awards research cycle has now begun – don’t miss on this opportunity be recognised in 2023
An intense period of lobbying and persuasion is under way as the UN secretary-general’s report on the future of international tax cooperation begins to take shape. Ralph Cunningham reports.
Fresh details of the European Commission’s state aid case against Amazon emerge, while a pension fund is suing Amgen over its tax dispute with the Internal Revenue Service.
The OECD’s rules may be impossible for businesses to manage, according to tax experts from companies including Shell.