Argentina enacts tax amnesty provisions and other significant tax changes

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

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.

Edelstein-Andres
Rodriguez-Ignacio

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 (andres.m.edelstein@ar.pwc.com) and Ignacio Rodríguez (ignacio.e.rodriguez@ar.pwc.com), Buenos Aires

PwC

Tel: +54 11 4850 4651

Website: www.pwc.com/ar

more across site & shared bottom lb ros

More from across our site

The Institute of Chartered Accountants in England and Wales also queried whether HMRC resources could be better spent scrutinising larger entities
Grant Thornton’s Austria tax head likens his practice to an escape room, shares his football coaching ambitions, and explains why tax is cool
Awards
ITR is delighted to reveal all the shortlisted nominees for the 2025 EMEA Tax Awards
Awards
ITR is delighted to reveal all the shortlisted nominees for the 2025 Asia-Pacific Tax Awards
The fates of pillars one and two hang in the balance after the US successfully threw its weight around in G7 and Canadian negotiations
Rafael Tena tells ITR about the ‘crazy’ Mexican market, ditching the hourly rate, and refusing to grow his fledgling firm in an ‘unstructured way’
It should be easy for advisers to be transparent about costs, Brown Rudnick partner Matthew Sharp said in response to exclusive ITR in-house data
The sprawling legislation phases out Joe Biden-era green tax incentives for businesses; in other news, the UK will reportedly maintain its DST despite US pressure
New French legislation should create a more consistent legal environment for taxing gains from management packages, say Bruno Knadjian and Sylvain Piémont of Herbert Smith Freehills Kramer
The South Africa vs SC ruling may embolden the tax authority to take a more aggressive approach to TP assessments, an adviser tells ITR
Gift this article