ARGENTINA Law and Practice Contributed by: Juan McEwan and Agustín Lacoste, McEWAN
create new national taxes on assets or increase the tax rate on PAT. • On 12 October 2018, the National Executive Branch submitted a bill to ratify amendments to the previously mentioned fiscal consensus. Item (e) of the bill provided for the suspension of the commit - ment assumed by the national government. • Law 27.480 (21 December 2018) raised the mini - mum taxable base and the fixed 0.25% tax rate was finally replaced by a progressive scale (up to 0.75% tax rate). • Law 27.541 (23 December 2019) raised tax rates once again through a progressive scale ranging between 0.5% and 1.25% and delegated to the executive branch the power to establish differential rates for assets held outside Argentina, which have been finally raised to up to 2.25%. • Law 27.667 (31 December 2021) again raised tax rates, which now range within a progressive scale between 0.5% and 1.75% for domestic property and from 0.7% to 2.25% for assets held abroad. • Besides PAT, a one-off extraordinary contribution levied on the assets held by individuals and undi- vided estates (both residents and non-residents) was enacted in 2020. This tax was known as aporte solidario y extraordinario or impuesto a la riqueza . • Law 27.743 (27 June 2024) – as mentioned in 1.1 Tax Regimes (Personal Asset Tax – Amendments to Legislation) – established a single progressive tax rate for domestic and foreign assets alike, ranging from 0.5% to 1.5% for fiscal year 2023. Furthermore, it provides a reduction of tax rates for the following fiscal years: (a) fiscal year 2024 ‒ from 0.5% to 1.25%; (b) fiscal year 2025 ‒ from 0.5% to 1%; (c) fiscal year 2026 ‒ from 0.5% to 0.75%; and (d) fiscal year 2027 ‒ a flat rate of 0.25%. • An optional Simplified Tax Return Regime for PIT ( Régimen de Declaración Jurada Simplificada ), was introduced under Law 27.799 and Decree 93/2026, available since fiscal year 2025 to resident individu - als and undivided estates meeting certain income and net-worth thresholds who do not qualify as large taxpayers. The tax liability is the same as under the general regime, but the return is pre-filled by the tax authority and taxpayers are relieved of the obligation to report net worth at year-start and
year-end, annual consumption, and the justification of net-worth variations. Timely filing and payment produces a discharging effect and a conclusive presumption of accuracy for both income tax and VAT, unless the authority identifies a significant discrepancy in the base period. For private clients, this is particularly relevant because it substan - tially narrows the authority’s ability to challenge unexplained net worth increases or bank depos - its for the covered period – a common source of exposure for individuals with cross-border assets, foreign-currency holdings, or complex international structures whose annual net worth reconciliation can otherwise be difficult to fully document. Enrol - ment is voluntary and reversible, so eligibility and convenience should be assessed case by case. Other tax simplification measures currently under dis - cussion include: • consolidating or eliminating minor national taxes, such as the bank transaction tax, which is widely considered distortionary; • adjusting PIT brackets and thresholds to reflect inflation, which has increasingly impacted middle and high-income earners; and • reducing the corporate income tax rate, which currently results in an effective rate of 39.5% when accounting for both corporate-level taxation and the withholding tax on dividends distributed to shareholders. 1.7 Transparency and Increased Global Reporting Following the international standards suggested by the OECD, fiscal transparency through controlled for - eign company (CFC) rules was introduced for the first time in Argentina by Law 27.430 (27 December 2017). Fiscal Transparency for Individuals Fiscal transparency rules apply primarily to individuals who hold shares or have an interest ownership in for - eign companies located in non-cooperative or low or nil tax (LONT) jurisdictions, modifying the moment of recognition of foreign-source income by resident tax - payers. In this way, the income will be recognised as having been earned by an Argentine resident as if the foreign entity does not exist, to the extent that certain
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