Who this article is for
This article is intended for foreign nationals who have moved or plan to move to Argentina and maintain income and/or assets abroad. The Argentine tax system reaches these taxpayers progressively depending on their permanence: as permanence in the country consolidates, tax obligations expand to encompass all income and assets, regardless of where they are generated or located.
The interaction between the migration regime and the tax regime is neither automatic nor immediate. The acquisition of tax residency follows criteria specific to tax legislation that, while linked to permanence, operate under their own rules and timelines. For a detailed analysis of when tax residency is acquired and lost, we recommend consulting our article on tax residency in Argentina.
Migration residency and tax residency are distinct concepts. It is possible to be a migration resident without being a tax resident, and vice versa. Joint planning of both aspects is essential to avoid unforeseen tax obligations.
The worldwide income principle
Once tax residency is acquired under Art. 116 of the Income Tax Law (LIG) — either through obtaining permanent migration residence or after twelve (12) months of temporary authorization — Art. 1 LIG establishes that residents are taxed on all their income, both from Argentine and foreign sources. This is known as the worldwide income principle.
The mechanism to avoid international double taxation, in the absence of a Double Taxation Treaty (DTT), is the tax credit for analogous taxes paid abroad. Taxes effectively paid in another country on foreign-source income can be credited as a payment on account of Argentine income tax, up to the limit of the tax increase caused by incorporating such foreign income. In other words, the credit cannot exceed the portion of Argentine tax attributable to foreign-source income.
Citizenship-by-investment exception. Art. 194 of Law 27,802 expressly provides that naturalization obtained through the citizenship-by-investment program does not by itself create tax residency. Those who obtain Argentine citizenship exclusively through this pathway are not subject to the worldwide income principle by the mere fact of naturalization.
Argentine source and foreign source: how to distinguish them
The Income Tax Law distinguishes between Argentine-source income and foreign-source income. This distinction is fundamental because it determines how each type of income is taxed and what tax credits may be claimed.
Source principle (Art. 5 LIG)
Argentine-source income is that which derives from assets located, placed, or economically used in the Republic, from the performance within the territory of any act or activity capable of producing profit, or from events occurring within it. The nationality, domicile, or residence of the holder is irrelevant, as is the place where contracts are executed: the determining factor is where the asset is located or where the activity is performed.
By exclusion, income that does not qualify as Argentine source under these criteria constitutes foreign-source income.
Practical examples for the foreigner residing in Argentina
| Situation | Source | Legal basis |
|---|---|---|
| Works remotely from Buenos Aires for a foreign company (employment relationship) | Argentina | Art. 5: activity performed in Argentine territory |
| Works remotely from Buenos Aires for a foreign client (freelance) | Argentina | Art. 5: activity performed in Argentine territory |
| Receives salary from an Argentine company | Argentina | Art. 5: activity and payer in Argentina |
| Receives rent from property in their country of origin | Foreign | Asset located outside Argentina |
| Receives rent from property in Buenos Aires | Argentina | Asset located in Argentina |
| Receives dividends from an Argentine company | Argentina | Art. 7: issuer based in Argentina |
| Receives dividends from a foreign company | Foreign | Issuer based outside Argentina |
| Receives interest from a bank account abroad | Foreign | Capital placed outside Argentina |
| Receives interest from a fixed-term deposit in an Argentine bank | Argentina | Capital placed in Argentina |
| Sells shares of an Argentine company | Argentina | Art. 7: issuer based in Argentina |
| Sells shares of a foreign company | Foreign | Issuer based outside Argentina |
| Receives royalties for intellectual property licensed from Argentina | Argentina | Art. 5: asset economically used in the territory |
| Receives a pension or retirement benefit from their country of origin | Foreign | Originated abroad |
| Exports goods produced in Argentina | Argentina | Art. 9: goods produced in the country |
The tax resident (Art. 116) is taxed on both sources — worldwide income (Art. 1 LIG). The non-resident is taxed only on Argentine-source income, through withholding (Art. 102).
Remote work: a point of attention
Under the territoriality principle of Art. 5 LIG, labor or professional activity physically performed from Argentina generates Argentine-source income, regardless of where the employer or client is located. This has direct implications for foreigners who work remotely from the country for foreign companies or organizations.
The impact of double taxation treaties
Argentina has bilateral treaties in force with more than 20 countries, including Germany, Australia, Brazil, Canada, Chile, China, Spain, France, Italy, Mexico, the United Kingdom, Russia, and Switzerland. International treaties have supra-legal hierarchy (Art. 75, paragraph 22, National Constitution), meaning that if a DTT allocates taxing rights differently from domestic law, the treaty prevails.
For illustrative purposes, the DTT in force between Argentina and Spain provides in its Article 15 that salaries from dependent employment are taxed in the country of residence of the employee, unless the employment is exercised in the other State and certain conditions are met (presence exceeding 183 days, employer resident or permanent establishment in that other State). Regarding independent professional services (Art. 14 of the same treaty), taxing rights are assigned to the country where the services are performed, with specific limitations.
Each DTT is different. The rules for allocating taxing rights vary substantially from one treaty to another. The foreigner's nationality determines whether an applicable DTT exists and which rules prevail over Argentine domestic law. The analysis must be done on a case-by-case basis, with the text of the specific treaty.
In all cases, the specific treatment varies depending on the type of income, its source, and applicable DTTs, requiring professional advice. Each case presents particularities that depend on the taxpayer's nationality, asset structure, income sources, and treaties in force between Argentina and the country of origin of the income.
The Argentine tax system reaches the worldwide income of its tax residents. For the foreigner who relocates, tax planning is not optional — it is a necessity.
Withholding on payments to non-residents
The reverse side of the worldwide income principle is the withholding regime applicable to foreign beneficiaries. Before acquiring tax residency — or if the foreigner never acquires it — Argentine-source income is subject to a withholding-at-source regime.
Art. 102 LIG establishes that payments to foreign beneficiaries are subject to a 35% withholding on presumed net income, as a single definitive payment. Presumed net income percentages vary by type of income:
| Type of income | Presumed net income | Effective withholding |
|---|---|---|
| Technical assistance, engineering or consulting not locally available | 60% | 21% |
| Fees to transient professionals (intellectuals, artists, athletes — less than 6 months) | 70% | 24.5% |
| Rental of movable property by foreign lessors | 40% | 14% |
| Rental of real estate in Argentina by foreign owners | 60% | 21% |
| Other income not covered by the above categories | 90% | 31.5% |
To access DTT benefits — which may significantly reduce these rates — the foreign beneficiary must present a Tax Residency Certificate issued by the competent authority of their country of residence, in accordance with current regulations on treaty application.
Single definitive payment: the non-resident does not file a tax return in Argentina. The withholding made by the local payer exhausts the tax obligation. This simplifies the situation, but also means that no deductions or expenses can be credited against these withholdings.
Personal assets tax: assets abroad
The Personal Assets Tax (Bienes Personales) complements income tax by taxing the taxpayer's wealth. Art. 17 of the Personal Assets Tax Law establishes the nexus criterion: residents are taxed on all their assets, both those located in Argentina and those abroad. Non-residents, conversely, are only taxed on assets situated in Argentine territory.
From the perspective of a foreigner moving to Argentina, this means that upon acquiring tax residency, their entire foreign wealth becomes subject to the tax. Taxable assets include:
- Real estate located outside Argentina
- Bank accounts in foreign financial institutions
- Securities and financial instruments issued by foreign entities
- Vehicles and vessels registered abroad
- Corporate participations in entities incorporated outside Argentina
- Receivables from debtors domiciled abroad
The tax base and rates are periodically updated by legislation. The valuation of assets located abroad follows specific rules that differ depending on the type of asset. The practical consequence is clear: moving to Argentina with wealth abroad means the Personal Assets Tax will apply to all of it, which must be evaluated and planned before relocation.
Automatic exchange of information: CRS and FATCA
A critical aspect for foreigners moving to Argentina is understanding that their accounts abroad will be automatically reported to the Argentine tax authority (ARCA, formerly AFIP). This mechanism operates through two main regulatory frameworks:
CRS (Common Reporting Standard)
Argentina has participated in the automatic exchange of financial information under the OECD CRS standard since 2017, implemented locally through RG 4056. Currently, 78 jurisdictions exchange information with Argentina. Financial institutions in those countries identify accounts held by Argentine tax residents and report their balances, interest, dividends, and sale proceeds to the local tax authority, which then transmits that information to ARCA.
In July 2025, Argentina signed the CRS 2.0 framework, which extends the scope of automatic exchange to digital assets and tokenized instruments, closing a significant regulatory gap for those holding crypto-assets on foreign platforms.
FATCA (Foreign Account Tax Compliance Act)
Argentina and the United States signed a Model 1 intergovernmental agreement (IGA) in December 2022, currently in force. Under FATCA, US financial institutions report the accounts of Argentine residents. The scope is limited to individuals (it does not cover corporations or trust structures) and covers gross US-source income: interest, dividends, and other financial returns.
Reverse exchange
The mechanism operates in both directions. Argentine financial institutions report to ARCA the accounts held by tax residents of other countries. ARCA, in turn, transmits that information to the tax authority of the account holder's country of residence. This means your Argentine accounts will be reported to the tax authority of your country of origin.
Important: automatic exchange of financial information between jurisdictions is an operational reality. ARCA systematically receives information about accounts and assets of Argentine tax residents abroad, and cross-references it with taxpayers.s filed returns.
Tax planning before the move
Tax planning is an essential component of the relocation process to Argentina. The timing of entry into the country has direct implications: the month of arrival may determine when Art. 116 LIG is triggered and, with it, subjection to the worldwide income principle.
Critical aspects that must be evaluated before the move include:
- Exit tax from the country of origin: many countries tax departing tax residents on unrealized gains. This tax must be planned and, in some cases, can be deferred or mitigated. Addressing it after the move may be impossible
- Timing of tax residency acquisition: coordination between the date of entry into Argentina and the rules of Art. 116 allows optimization of the transition period between both jurisdictions
- Asset structure: reviewing the composition of assets and their ownership before the move can avoid unfavorable tax situations. Once Argentine tax residency is acquired, reorganization options are significantly reduced
- Applicable DTTs: the existence and content of a double taxation treaty between Argentina and the country of origin directly affects the taxpayer's overall tax burden
- Coordination between migration and tax advisors: the disconnect between these two areas of advice is a frequent source of problems. Planning must be joint and comprehensive
Each case presents particularities that depend on the taxpayer's nationality, their asset structure, their income sources, and applicable DTTs. Undertaking planning after the move is significantly more complex and expensive — and in some cases, optimization opportunities have already been irreversibly lost.
Last updated: February 2026. Legislation cited: Income Tax Law 20,628 (Arts. 1, 102, 116, 117), Personal Assets Tax Law (Art. 17), Law 27,802 (Art. 194), RG 4056.