Repatriating capital and leaving Argentina: getting your money out

Key rules

1. The FX starting point: non residents need prior approval unless a listed exception applies

Point 3.13.1 of the FX rules says that access to the MLC "for the repatriation of investments of non residents and other purchases of foreign currency by non resident clients" requires BCRA prior approval, except for the operations listed in points 3.13.1.1 to 3.13.1.14. The list includes international organisations, diplomats, foreign pensioners and tourists. For investors, the relevant exceptions are these:

(a) Direct investment repatriation by time elapsed (point 3.13.1.7). A non resident can repatriate direct investment in a company that does not control a local financial entity, out of a capital contribution brought in and converted through the MLC from 2 October 2020, if: * the contribution was converted from 21 April 2025 and the repatriation takes place at least 180 calendar days after conversion (item i, introduced by Com. A 8230 point 2); or * the contribution was converted between 2 October 2020 and 20 April 2025 and the repatriation takes place at least 2 years after conversion (item ii).

Two points are not answered by the text. First, the rule is drafted around "a capital contribution". It does not expressly cap the repatriation at the US dollar amount originally converted, nor does it say whether a gain on that capital may also go out under this point (unconfirmed). Second, the text does not say whether a foreign shareholder who sells its stake for pesos to a local buyer can use 3.13.1.7 to repatriate the peso price. The specific rule for sales to residents is 3.13.1.10, which works through the buyer's access, so 3.13.1.7 is best read as covering payments by the company itself (capital reductions, refunds of contributions, liquidation) (unconfirmed).

(b) Capital reductions and refunds of irrevocable contributions (point 3.13.1, final paragraph). If the repatriation takes the form of a capital reduction or a refund of irrevocable contributions, the bank must also have two things on file, in addition to the requirements of the specific exception: * documents showing that "the legal mechanisms" (the LGS and IGJ steps) were completed; and * proof that the peso liability to the non resident arising from the reduction, or from the non acceptance of the contribution, is declared in the last due filing of the BCRA "Relevamiento de activos y pasivos externos" (external assets and liabilities survey).

(c) Sale to a resident buyer (point 3.13.1.10, text per Com. A 8331 of 18 September 2025). The resident buyer of a stake in a resident company can access the MLC to pay the non resident seller. The same applies to the buyer of 100% of a foreign company whose only asset is the stake in the resident company. All three conditions must be met: 1. the access takes place simultaneously with the conversion of funds from new foreign financial debt or debt securities under point 3.5, or from a foreign currency loan granted by a local bank out of a foreign bank's credit line. The financing must have an average life of at least 4 years and at least 3 years of grace for principal; 2. the company acquired is not a financial entity or the controller of one; and 3. the deal transfers at least 10% of the resident company's capital.

If the buyer acquires the foreign holding company, it must give a sworn statement with three undertakings: (a) to move the acquired foreign company's residence to Argentina within 12 months of the FX access; (b) that the local company will not pay dividends to the foreign holding company until that happens; and (c) if it later sells the foreign holding company to a non resident, to bring in and convert the price within 15 business days. If the buyer cannot yet document that it has taken possession of the stake, it undertakes to do so within 60 calendar days of the access.

Point 3.13.1.11 creates a parallel route for the sale of a non resident's interest in a natural resources concession to a resident. The same financing test applies, with a minimum of 10% of the concession interest.

(d) Portfolio investments (point 3.13.1.13). A non resident can repatriate principal and income collections and the proceeds of sale of portfolio investments in three kinds of asset: instruments listed on CNV authorised markets; unlisted mutual funds made up of those instruments; and sight or time deposits at local banks. Two conditions apply: * a local bank certifies that the investment was made with funds brought in and converted through the MLC from 21 April 2025. The conversion requirement is also met where the non resident applied foreign currency directly, from 23 May 2025, to primary subscriptions of National Treasury debt (Com. A 8245 point 2); and * documents show that the amount accessed does not exceed the collections or the sale proceeds actually received. If the collections or sale were received in foreign currency, the repatriation may be made for up to that amount.

The original Com. A 8230 (16 April 2025, point 3(iii)) also required the repatriation to take place at least 180 days after conversion. Com. A 8257 (12 June 2025, in force from 13 June 2025) "left without effect" item iii) of point 3 of Com. A 8230. It also added portfolio repatriations to the list in point 3.16.3.5, which exempts them from the 90 day cross restriction statements (Com. A 8257 points 1 and 2). Point 3.16.3.5(iv) of the consolidated text still refers to portfolio repatriations "under point 3.13.1.12". After renumbering, point 3.13.1.12 is now the RIGI exception and portfolio repatriation is point 3.13.1.13. This looks like a cross reference that was not updated (unconfirmed).

(e) BOPREAL routes (points 3.13.1.14, 3.13.3, 3.14.5 and 4.6). BOPREAL ("Bonos para la Reconstrucción de una Argentina Libre") are BCRA bonds that pay in foreign currency. The FX rules use them as an exit valve for trapped peso dividends in two ways: * Dividends pending payment (point 4.6.1). The resident company may subscribe BOPREAL for up to the peso amount of dividends pending payment to non resident shareholders under the shareholders' meeting resolution. The bank checks four things: the dividends come from closed and audited balance sheets; they are declared in the external survey; the complementary requirements in points 3.16.1 to 3.16.4 are met; and the company has signed a sworn statement. In that statement the company declares that it will not later access the MLC to pay the same debt, except through a swap of BOPREAL collections (point 4.6.1.4(iii)). * Dividends already collected in Argentina since 1 September 2019 (points 3.13.3 and 4.6.2). A non resident who received peso dividends on a local account, and has not sent them abroad, may subscribe BOPREAL for up to that peso amount adjusted by the latest CPI. The non resident's sworn statement includes the same waiver of later MLC access except through BOPREAL collections (point 4.6.2.3(iii)).

Once the BOPREAL pay principal or interest in foreign currency into a local account, those funds can be swapped or transferred abroad to repatriate the dividends (points 3.13.1.14 and 3.14.5.3 to 3.14.5.4). The series, maturities, availability of new issues and secondary market prices of BOPREAL are not in the project sources (unconfirmed). BOPREAL is therefore a route with a discount and a delay. It is not an immediate transfer.

(f) Other exceptions. * RIGI vehicles may repatriate qualifying contributions with no minimum stay (points 3.13.1.12 and 14.2.3). * Plan Gas investments may be repatriated after 2 years (point 3.13.1.8). * Holders of the Decree 277/22 oil and gas certificate may repatriate up to the certified amount (point 3.13.1.9). * Repatriation using export proceeds is allowed if the requirements of point 7.9 are met (point 3.13.2).

(g) The complementary checks still apply. Before any outflow, the bank checks the requirements of point 3.16 that apply. The liquid foreign assets statement in point 3.16.2 (USD 100,000 test) does not apply to operations under point 3.13. The 90 day cross restriction statements of point 3.16.3 do apply to clients other than resident individuals, except for portfolio repatriations (point 3.16.3.5(iv), as amended by Com. A 8257). Whether the 3.16.3 statements bite in practice on non resident individuals repatriating direct investment is not addressed expressly (unconfirmed). A resident buyer paying under 3.13.1.10 is a resident client and must give the full set of 3.16 statements, including the group statements of points 3.16.3.3 and 3.16.3.4 if it is a company. See /guide/fx/exchange-controls/ for the full list.

2. Who is a resident for FX purposes

The FX rules use their own residence test, which is not the tax test. An individual is resident in the country where they have their centre of economic interest or main activity. A person is presumed resident in a country if they stay, or intend to stay, there for at least one year (point 6.5.1). A legal entity is resident where it is incorporated. Branches of foreign entities registered to operate habitually in Argentina are residents (point 6.5.2). Trusts, funds and undivided estates follow the residence of the trustee or legal representative (point 6.5.3).

Consequence for people leaving: there is no formal act of "ceasing to be an FX resident". When the person's centre of economic interest moves abroad, they become a non resident client. From that point they fall under point 3.13 rather than points 3.8, 3.9 and 3.14.1. Banks apply the test on the documents they hold (unconfirmed).

3. Individuals: what the 2025 lifting of the cepo actually did

Com. A 8226 (11 April 2025, in force from 14 April 2025) allowed resident individuals to buy foreign currency for holding or deposits (concepts A07 and A09) without BCRA prior approval. Today's conditions, set out in point 3.8, are: * the purchase is debited from the client's account at a local bank. Cash purchases are limited to USD 100 a month (about ARS 156,390) across all banks; * the bank delivers banknotes or credits the funds to the client's own foreign currency account in Argentina or own bank account abroad; * the bank registers the operation in the BCRA online system; * the bank obtains evidence that the client has income or assets consistent with saving in foreign currency; and * the client undertakes not to buy securities settled in foreign currency for 90 calendar days after the access (point 3.8.5, reintroduced for all individuals by Com. A 8336 of 26 September 2025). There are exceptions for primary subscriptions held at least 15 business days and for reinvestment of Treasury or BCRA bond collections (points 3.8.5.1 and 3.8.5.2).

Separately, point 3.14.1 lets individuals transfer foreign currency from their local foreign currency accounts to their own bank accounts abroad. The bank must register the operation in the BCRA online system and obtain the same 90 day undertaking (points 3.14.1.1 and 3.14.1.2). Point 3.14.1 says "personas humanas" and, unlike point 3.8, does not add "residentes". Whether banks will process 3.14.1 transfers for clients they classify as non residents is not stated in the text (unconfirmed). Com. A 8417 (9 April 2026) provides for a new online system for these own account transfers, which applies once the BCRA announces it is available (Com. A 8417 point 7.1) (unconfirmed).

What did not change for companies. Legal entities still need prior approval to buy foreign currency for savings or investment abroad (point 3.10). For dividends, Com. A 8226 point 6 opened free access only for profits from fiscal years starting on or after 1 January 2025 (point 3.4.4.1). See /guide/fx/dividends-profits/.

4. Tax on a sale of shares or quotas by a foreign seller

Source and rate. ITL art. 98 taxes gains from selling shares, quotas and equity interests. For unlisted shares and quotas, the rate is 15% (art. 98(c)). The article "also applies when the seller is a foreign beneficiary" that is not resident in a non cooperative jurisdiction and whose funds do not come from one. In that case the gain is taxed under art. 104(i) and the second paragraph of art. 104 at the art. 98 rate (art. 98, penultimate paragraph). Art. 104(i) presumes a net gain of 90% of the amounts paid. So the default tax is 15% × 90% = 13.5% of the gross price.

The option for actual gain. RG 4227/2018 art. 7 says that the withholding is computed on 90% of the price "or, as the case may be, on the actual net gain determined under the second paragraph of art. 93" of the ITL (t.o. 1997 numbering, now art. 104). RG 4227 art. 8 describes the election. The seller tells the withholding agent or its representative that it opts to deduct the expenses incurred in the country, and provides the purchase and sale documents and the cost computation, including any inflation update. The agent keeps those papers for ARCA. In practice this is the "15% on the net gain" option.

A caveat on the legal basis: the second paragraph of art. 104 as printed in the Infoleg text names only items (g) and (h) (rent and transfers of property of foreign companies). Art. 98 nevertheless sends share gains to "inciso i) and the second paragraph" of art. 104, and Decree 862/2019 art. 249 does the same, "de corresponder". RG 4227 art. 7 applies the option to share sales. The option is therefore supported by the regulation and the ARCA resolution. A reader of the law alone could still argue that it is narrower (unconfirmed).

How the gain is computed under the option. For shares and quotas, the gross gain is the price minus the acquisition cost updated by the CPI index of ITL art. 93, second paragraph, from acquisition to sale (art. 98, item (ii)). For holdings acquired before Law 27.430, the cost is the last acquisition price or the last quoted value at 31 December 2017, whichever is higher (RG 4227 art. 13). Costs are measured in pesos and updated by CPI, not by the exchange rate. If the peso has depreciated faster than CPI since the investment, a foreign investor can show a large peso "gain" even with no gain in dollars. That is the main reason many foreign sellers end up on the 13.5% presumption.

Who pays. * Resident buyer: the buyer withholds and pays as a single and final payment (RG 4227 art. 6(a); ITL art. 102, last paragraph: if withholding is impossible, the payer bears the tax). Payment follows RG 3726 (the SIRE system) with the regime codes in RG 4227 art. 9(a) (unconfirmed). * Non resident buyer: the seller pays through its legal representative in Argentina (ITL art. 98, last paragraph; RG 4227 art. 6(d)). Decree 862/2019 art. 252 adds two more options: paying directly through an ARCA mechanism, or paying through a resident with sufficient mandate. If there is no representative, the foreign seller can pay by international bank transfer in US dollars or euros by midnight Argentine time on the 10th business day after the operation. The SWIFT MT103 field 70 must carry the CUIT of the company whose shares were sold and the code 10-366-366 (RG 4227 art. 9(b)). Late payment carries compensatory interest under Law 11.683 art. 37 (RG 4227 art. 9(b)(5)).

Indirect transfers. A sale of a foreign holding company is Argentine source income if two tests are met: at least 30% of the value of the interest sold comes from Argentine assets at the time of sale or in any of the prior 12 months; and the interest sold represents at least 10% of the foreign entity, counting related parties. The gain is taxed only in proportion to the Argentine assets (ITL art. 15).

Listed securities. Gains of foreign beneficiaries (not in non cooperative jurisdictions) on shares listed on CNV authorised markets and traded under the conditions of art. 26(u) are exempt. So are gains on government bonds, negotiable obligations, mutual fund units placed by public offer and ADRs of Argentine companies (ITL art. 26(u), first and fourth paragraphs). Most portfolio exits are therefore income tax free. Direct investment exits through a private sale of an unlisted SA or SRL are not.

Treaties. A tax treaty may limit or remove Argentina's right to tax the gain. There is no income tax treaty between Argentina and the United States in the project sources (the treaty files cover Australia, Austria, Belgium, Bolivia, Brazil, Canada, Chile, China, Denmark, Finland, France, Germany, Italy, Mexico, Netherlands, Norway, Qatar, Russia, Spain, Sweden, Switzerland, Turkey, UAE, UK and Uruguay). See /guide/taxes/treaties/ for capital gains articles.

5. Tax on dividends, capital reductions and liquidation distributions

• Dividends to foreign beneficiaries: 7% withholding, single and final (ITL art. 97). Dividends are excluded from the general 35% withholding of art. 102. Details: /guide/fx/dividends-profits/.
• Redemptions and capital reductions. In a total or partial redemption of shares, the excess of the redemption amount over the computable cost of the shares is a dividend (ITL art. 49, fourth paragraph). The computable cost per share is the equity in the last closed commercial balance before the redemption, minus liquid and realised profits and the reserves that come from them, divided by the shares outstanding (art. 49, fifth paragraph). If the redeemed shares were bought from other shareholders, the redemption is treated as a sale of those shares (art. 49, last paragraph). Art. 49 speaks of "acciones". Whether it applies word for word to a reduction of SRL quotas, and how the capital adjustment account is treated, is not settled in the sources (unconfirmed). The common working assumption is that the return of paid in capital is not income and the part representing accumulated profits is a 7% dividend.
• Liquidation distributions: see /guide/exiting/dissolution/, section 8.2, which uses the same reading of art. 49.
• Personal assets tax on the shares. Until the exit date, the company pays 0.50% of the equity value of shares or quotas held by foreign individuals and foreign companies at each 31 December, as a single and final payment. It can recover that amount from the shareholder, including by withholding (Law 23.966 Title VI, unnumbered article after art. 25, text per Law 27.541 art. 29). In a share sale this becomes a price adjustment item.

6. Corporate law steps for a capital reduction (LGS arts. 203 to 206, art. 83)

• Voluntary reduction must be resolved by an extraordinary shareholders' meeting, with a reasoned report of the statutory auditor (síndico) if there is one (LGS art. 203). In an SRL, the equivalent is a resolution amending the contract. The majority is set by the contract and must be more than half of the capital. If the contract is silent, three quarters of the capital is needed, and if one partner holds the majority, another partner's vote is also required (LGS art. 160).
• Creditor opposition. The reduction gives creditors the right regulated in art. 83 and must be registered after the publication that art. 83 requires (LGS art. 204). Art. 83 requires a notice published for 3 days in the official gazette of the company's jurisdiction and in a major newspaper (art. 83(3)). Creditors with earlier claims may oppose within 15 days of the last publication. Opposition does not stop the process. In mergers, the final step cannot be taken until 20 days after that period expires, so that unpaid or unsecured opponents can obtain a court attachment (art. 83(3), last paragraph). Art. 204 still refers to "art. 83, inciso 2", a numbering left over from before the creditor paragraph moved to item 3. IGJ RG 15/2024 art. 235 refers to "arts. 204 and 83, inciso 3°, último párrafo" (unconfirmed).
• Exception. Art. 204 does not apply when the reduction is made by redeeming fully paid shares with profits or free reserves (art. 204, second paragraph).
• Reduction for losses may be resolved to restore the balance between capital and equity (art. 205). It is mandatory when losses absorb the reserves and 50% of the capital (art. 206). The Infoleg text notes that art. 206 was suspended by Law 27.541 art. 59 "until the end of the period established in art. 1" of that law (unconfirmed).
• IGJ filing (CABA companies). IGJ RG 15/2024 art. 97 (all reductions) requires three items: the deed or original private instrument with the minutes of the meeting, which must state the type of reduction; the balance sheet, or for voluntary reductions a special balance sheet at the effective date, with an audit report; and a report from the legal representative on how the reduction will be carried out. Art. 98 (voluntary reductions) adds three more: a comparative statement of financial position before and after; a reasoned report of the síndico, supervisory council or auditor on reasonableness and on third party and partner equality, which the meeting must expressly consider; and the 3 day publication, stating that it is made for creditor opposition purposes and giving the amounts of assets, liabilities and equity before and after. The deed must list opposing creditors and how they were treated, or state that there were none.
• Irrevocable contributions. Under IGJ RG 15/2024 art. 235, irrevocable contributions form part of equity unless they are expressly rejected and their return is resolved, or an acceptance deadline expires. In those cases they become a liability and may be returned "applying the creditor opposition regime of arts. 204 and 83, inciso 3°, último párrafo" of the LGS. Until capitalised, the contributor's claim is subordinated in insolvency.

7. Corporate law steps for a sale of SRL quotas

• Quotas are freely transferable unless the contract provides otherwise (LGS art. 152). The contract may limit transfer but not prohibit it. Clauses requiring partner consent or giving a preference right are valid if the contract sets a procedure. The partners or the company must answer within 30 days of being told the buyer's name and the price, failing which consent is deemed given and the preference waived (art. 153).
• The transfer is effective against the company once a copy of the transfer instrument is delivered to the management, with signatures certified if it is a private document. It is effective against third parties once registered in the Public Registry (art. 152).
• IGJ registration requires the transfer instrument, proof of the notice to management, and, where applicable, the spouse's consent under CCyC art. 470 and proof of partner consent for restricted quotas (IGJ RG 15/2024 art. 115). The recitals of RG 15/2024 state that the publication of edicts for SRL quota transfers was eliminated (recital 37).

8. Individuals leaving: loss of tax residence (ITL arts. 116 to 122)

• Becoming resident. A foreigner becomes an Argentine tax resident when they obtain permanent residence, or after 12 months of stay under temporary migration permits. Absences of up to 90 days, consecutive or not, within each 12 months do not interrupt the stay (ITL art. 116(b); Decree 862/2019 art. 281). Residence takes effect from the first day of the month after the condition is met (art. 116, paragraph after (f)). Foreigners present for work for up to 5 years, and students and researchers on temporary permits, are not residents (art. 123(c) and (d)).
• Losing residence. A resident loses that status when they acquire permanent residence in a foreign State under its migration rules, or, if that has not happened first, when they stay abroad continuously for 12 months. Presences in Argentina totalling up to 90 days in each 12 month period do not interrupt the stay abroad (ITL art. 117; Decree 862/2019 art. 283). The loss takes effect from the first day of the month after the foreign permanent residence is obtained or the 12 months are completed (art. 117, last paragraph).
• Procedure. If the loss happens before the person leaves, they must prove the foreign residence to ARCA. They must also comply with income tax on Argentine and foreign source income for the part of the fiscal year up to the end of the month after the foreign residence was acquired, and for open years that ARCA specifies. If the loss happens after they leave, the proof is filed at the Argentine consulate, which informs ARCA (ITL art. 119). RG 4236/2018 art. 2 lists the accepted evidence: a foreign permanent residence certificate, or a passport, consular certificate or other reliable document proving exit and stay abroad for the required period. The evidence is attached to the request to cancel the income tax registration under RG 2322, with a sworn translation and apostille where applicable. Until cancellation, all formal and substantive obligations continue (RG 4236 art. 2) (unconfirmed).
• After the loss. The person is a foreign beneficiary for Argentine source income from the date the loss takes effect. They must tell withholding agents (ITL art. 120). Withholdings omitted before the notice must be made on later payments, or reported to ARCA if that is impossible (art. 120, second paragraph).
• Dual residence. If a person who obtained foreign permanent residence keeps living in Argentina, or comes back, the tie breakers are: permanent home in Argentina, then centre of vital interests, then habitual abode (measured by calendar year, Decree 862/2019 art. 284), then nationality (ITL art. 122). RG 4236 art. 3 defines "permanent home" by availability, whatever the legal title. It defines "centre of vital interests" with priority to personal over economic ties, and gives treaty rules priority where a treaty applies.
• Open question for foreign nationals. Art. 117 speaks of acquiring permanent residence "in a foreign State". A foreigner returning to their country of nationality usually does not obtain a "permanent residence" there, because citizens do not need one. The text does not say whether returning home triggers the first limb or whether the person must wait 12 months (unconfirmed).

9. Personal assets tax when leaving

• Residents are taxed on worldwide assets above the non taxable minimum at 31 December. For 2026 the scale is 0.50% up to ARS 13,688,704.13 of excess and 0.75% above (amounts indexed annually). For 2027 there is a flat 0.25% (Law 23.966 Title VI, art. 25, as replaced by Law 27.743 art. 63). The 2025 non taxable minimum published by ARCA was ARS 384,728,044.57 (about US$246,006); the 2026 figure is indexed (unconfirmed).
• Non residents are taxed only on Argentine assets, through the local co owner, holder, custodian or administrator, at 0.50%, as a single and final payment (art. 26, rate per Law 27.541 art. 31). Shares and quotas in Argentine companies are taxed through the company at 0.50% (art. 25.1).
• So the 31 December on which the person is still a resident matters. If they hold the home sale proceeds abroad on that date, the proceeds are part of the worldwide base.

10. Real estate sale proceeds

• Income tax. ITL art. 99 taxes individuals' gains on Argentine real estate at 15% on price minus CPI indexed cost and expenses. It applies to properties acquired from 1 January 2018, as defined in Decree 862/2019 art. 255. Law 27.802 art. 192 (BO 6 March 2026) added to ITL art. 26(n) an exemption for results of sales and transfers of rights over real estate covered by art. 99 made from 1 January 2026, "in the terms established by the regulations". Decree 406/2026 (BO 1 June 2026, in force on publication) added an article after art. 83 of Decree 862/2019. It provides that individuals and undivided estates, "resident in the country or abroad", enjoy the exemption for sales and transfers of rights over Argentine real estate covered by art. 99 made from 1 January 2026. It covers both sales (ITL art. 3) and assignments of purchase contracts without possession (Decree 862/2019 art. 254).
• Properties acquired before 2018. These were subject to the ITI (Law 23.905 Title VII), not to art. 99 (Decree 862/2019 art. 255, with special rules for works in progress and pre 2018 purchase contracts with at least 75% paid). The ITI was repealed from 8 July 2024 (Law 27.743 art. 67). On the texts reviewed, an individual selling a pre 2018 property after that date pays neither ITI nor art. 99 tax (unconfirmed).
• Foreign companies selling Argentine real estate are outside the individuals' exemption. The withholding is 35% on a presumed gain of 50% of the price, an effective 17.5%, unless the actual gain option is used (ITL arts. 102 to 104(h)). See /guide/real-estate/foreign-ownership/.
• Notary withholding. AFIP RG 2139/2006 makes notaries withholding agents on real estate transfers. For sellers resident abroad, the notary withholds the amount stated in a certificate issued by ARCA at the request of the seller's representative, filed at least 20 calendar days before the deed (RG 2139 art. 20, as summarised in /guide/real-estate/foreign-ownership/). The project sources do not show whether ARCA has adapted RG 2139 to the 2026 exemption and the repeal of ITI (unconfirmed).
• COTI. The former transfer code regime (RG 2371) was abrogated by ARCA RG 5697/2025 (BO 23 May 2025), as noted in /guide/real-estate/foreign-ownership/.
• Stamp tax is provincial. Under the Fiscal Consensus 2021 (Law 27.687), adhering jurisdictions agreed a maximum rate of 3.5% for real estate transfers (clause THIRD (c)). The actual CABA or provincial rate, base and housing exemptions are not in the sources (unconfirmed).

11. Exiting ARCA registrations

• Individuals: cancel the income tax registration with the RG 4236 evidence (above). If they were registered for personal assets tax, VAT or the simplified regime (monotributo), each needs its own cancellation (unconfirmed). A non resident who keeps Argentine assets or needs to deal with banks and registries gets a CUIT through a representative or authorised third party domiciled in Argentina (ARCA, "CUIT y CDI, Residentes en el exterior"). Keeping a valid CUIT or CDI is often necessary to close bank accounts and collect final amounts.
• Companies: the corporate route (dissolution and cancellation, or sale of the company) determines the tax route. A sold company keeps its CUIT. A liquidated company must cancel its registrations as part of the liquidation; see /guide/exiting/dissolution/.
• Representative. A foreign seller of shares to a non resident buyer needs a legal representative in Argentina to pay the tax (ITL art. 98, last paragraph), unless it pays by international transfer (RG 4227 art. 9(b)).

Step by step

A. Foreign parent selling an Argentine SRL or SA to a local buyer

1. Check the FX route first. Decide how the buyer will pay:
2. (i) abroad, out of funds the buyer already holds outside Argentina;
3. (ii) through the MLC under point 3.13.1.10, with matching new foreign financing (4 years average life, 3 years grace, at least 10% of capital);
4. (iii) in pesos, with the seller then facing point 3.13.1 prior approval; or
5. (iv) BCRA prior approval.

Route (i) is not an MLC operation. It does affect the buyer: its liquid foreign assets above USD 100,000 can block its own later MLC access under point 3.16.2, and the cross restriction under point 3.16.3 applies if it later sells securities for foreign currency (unconfirmed). Route (iii) leaves the seller with pesos and no listed exception that clearly fits a private sale (see Key rules 1(a)). 2. Tax choice. The seller decides whether to elect the actual gain option. If so, it assembles the acquisition documents and the CPI indexed cost computation and gives them to the buyer (RG 4227 art. 8). 3. Representative and tax ID. Make sure the seller has a CUIT through a representative, or another way to deal with ARCA. 4. Corporate approvals. In an SRL, follow the contract's consent or preference procedure (LGS art. 153, 30 days). In an SA, follow the share transfer restrictions in the bylaws (unconfirmed). 5. Signing and closing. At closing, the buyer withholds the tax and pays it through SIRE (RG 4227 art. 9(a); RG 3726). It delivers the withholding certificate to the seller for its home country foreign tax credit. 6. FX access (route ii). On closing day, the buyer's bank converts the foreign financing and sells foreign currency to the buyer for the transfer to the seller. The buyer gives the 3.16 statements. If possession documents are not yet available, the buyer undertakes to file them within 60 days. 7. Registration. For an SRL: notice to management, then IGJ registration (LGS art. 152; IGJ RG 15/2024 art. 115). For an SA: the share register entry (unconfirmed). 8. Personal assets tax. Agree in the contract who bears the company's 0.50% substitute tax for the year of sale (Law 23.966 art. 25.1). 9. Post closing. The buyer declares the new foreign debt and the change in foreign ownership in the BCRA external survey (unconfirmed). The seller declares the gain at home with the Argentine withholding certificate.

B. Repatriating through a capital reduction

1. Confirm the original contribution was converted through the MLC and when (bank certificate). The relevant periods are: from 21 April 2025, wait 180 days; from 2 October 2020 to 20 April 2025, wait 2 years; before 2 October 2020, no listed exception, so prior approval is needed (unconfirmed).
2. Prepare the special balance sheet with audit report and the síndico or auditor report (IGJ RG 15/2024 arts. 97 and 98).
3. Hold the extraordinary meeting or partners' resolution (LGS arts. 160, 203).
4. Publish for 3 days (LGS art. 204; IGJ art. 98(3)). Wait 15 days for oppositions (art. 83(3)) and deal with any opposing creditors by paying or securing them.
5. File with the IGJ (arts. 97 and 98). Once registered, declare the peso liability to the shareholder in the BCRA external survey (point 3.13.1, final paragraph).
6. Compute the tax: the part above the computable cost is a dividend (ITL art. 49), and the 7% withholding applies to that part (art. 97).
7. Access the MLC with the bank file: corporate documents, survey proof, contribution conversion certificate, and the 3.16 statements.

C. Individual selling a home and leaving

1. Before signing, check the acquisition date. If the home was acquired from 1 January 2018, the art. 99 exemption applies to sales from 2026. If it was acquired earlier, there is no ITI after July 2024. Collect the title deed and the acquisition cost evidence anyway, because the bank will ask for proof of the origin of the funds.
2. Agree the currency. A price in US dollars, paid in banknotes at the deed or by transfer to the seller's local US dollar account, avoids the need to buy dollars in the MLC.
3. Notary. Ask the notary how they will handle income tax withholding after Decree 406/2026. If the seller is already a non resident, check whether the RG 2139 certificate procedure is still required (unconfirmed).
4. Deposit and transfer. Deposit the dollars in the seller's own local US dollar account. While still an FX resident, the seller orders a transfer to their own foreign account under point 3.14.1 and signs the 90 day securities undertaking. If paid in pesos, the seller buys dollars under point 3.8 by debit to their account. The deed is the evidence of assets consistent with the purchase (point 3.8.4).
5. Leave and prove the loss of residence. Obtain the foreign permanent residence certificate, or keep travel evidence for the 12 months. Request cancellation of the income tax registration with the RG 4236 evidence. File the final resident return for the part of the year (ITL art. 119).
6. Personal assets tax. File the personal assets return for each 31 December on which the seller was still a resident.
7. Keep a CUIT through a representative if any Argentine assets, bank accounts or pending collections remain.

Costs and timelines

Table 1. Rates

Table 2. FX thresholds and conditions

Table 3. Deadlines and waiting periods

Table 4. Timeline of norms

BCRA communications are dated by the BCRA. Their Boletín Oficial dates are not in the project sources (unconfirmed).

Worked examples

Example 1. A US parent sells its Argentine SRL to a local buyer for USD 3,000,000

Facts (assumed for the example). * Delaware Parent Inc. holds 95% of the quotas of an SRL in CABA. Its wholly owned US affiliate holds 5%. * A local company ("Buyer SA") buys 100% of the quotas for USD 3,000,000, that is ARS 4,691,700,000 at the 23 Oct 2026 dólar MEP rate. Each seller receives its pro rata share. * There is no Argentina and US tax treaty in the sources, so domestic law applies. * Buyer SA has arranged a USD 3,000,000 loan from a foreign bank with a 5 year bullet maturity: average life 5 years and 4 years of grace on principal. * The SRL's equity at 31 December 2025 was ARS 3,127,800,000 (US$2,000,000). * The sellers' CPI indexed peso cost of the quotas is assumed at ARS 2,815,020,000 (US$1,800,000 at today's rate). This is an assumption, not a computed figure. The real figure requires the historical subscriptions and the ITL art. 93 index (unconfirmed). * Expenses incurred in Argentina (local counsel, notary) are ARS 31,278,000 (US$20,000).

Step 1. Tax, default presumption. * Presumed net gain: 90% × ARS 4,691,700,000 = ARS 4,222,530,000 (ITL art. 104(i)). * Tax: 15% × ARS 4,222,530,000 = ARS 633,379,500 (US$405,000), that is 13.5% of the price.

Step 2. Tax, actual gain election (RG 4227 arts. 7 and 8). * Gross gain: ARS 4,691,700,000 minus ARS 2,815,020,000 = ARS 1,876,680,000. * Minus expenses in Argentina: ARS 31,278,000. Net gain = ARS 1,845,402,000 (US$1,180,000). * Tax: 15% × ARS 1,845,402,000 = ARS 276,810,300 (US$177,000). * Saving versus Step 1: ARS 356,569,200 (US$228,000). The election only works if the documents support the indexed cost. If the peso cost was low because the capital was subscribed years ago at a much stronger peso, the CPI update may not keep up with depreciation, and the presumption can then be cheaper. Run both numbers.

Step 3. Who withholds and pays. Buyer SA is a resident, so it withholds the tax from the price and pays it through SIRE under RG 3726, using the RG 4227 regime codes (RG 4227 arts. 6(a), 9(a)) (unconfirmed). With the election, it keeps the sellers' cost documents (art. 8).

Step 4. FX. * Buyer SA's bank converts the USD 3,000,000 loan in the MLC. In the same operation, it sells Buyer SA the dollars needed to pay the sellers abroad, under point 3.13.1.10. * The tax withheld is a peso obligation. Buyer SA pays it in pesos, so it needs to convert only the net price. * All conditions are met: financing with an average life of 5 years (≥ 4) and 4 years of grace (≥ 3); the target is not a financial entity; and 100% of the capital is transferred (≥ 10%). * Buyer SA gives the 3.16 statements, including the 90 day cross restriction and the group statements. * Because the IGJ registration of the quota transfer may come later, Buyer SA signs a sworn statement undertaking to file proof of possession within 60 calendar days.

Step 5. Net proceeds to the sellers.

The bank's FX spread and transfer charges, CABA stamp tax on the transfer instrument (unconfirmed), and the IGJ fee (unconfirmed) are not included.

Step 6. What if Buyer SA has no foreign financing? In that case the parties have three options: * (a) Buyer SA pays offshore from its own foreign funds; see the caveats in procedure A.1. * (b) The parties ask the BCRA for prior approval. * (c) The sellers accept pesos and look for a later exit. No listed route fits well. Point 3.4 covers dividends, and the sellers are no longer shareholders. The BOPREAL routes cover dividends, not sale proceeds. The portfolio route requires funds converted in the MLC from 21 April 2025, and peso sale proceeds do not qualify.

In short, a foreign seller who takes pesos for a private sale is likely to be stuck without prior approval (unconfirmed).

Timeline. * Week 0: signing. * Weeks 0 to 4: preference and consent procedure under the SRL contract (maximum 30 days, LGS art. 153). * Closing day: withholding, loan disbursement and FX access. * Within 60 days: IGJ registration of the transfer and proof of possession to the bank.

Cost to do it: tax of US$177,000 to US$405,000; professional fees; IGJ fee and stamp tax (unconfirmed); 1 to 3 months.

Example 2. A foreign resident sells a USD 250,000 apartment and leaves Argentina

Facts (assumed). * A foreign national (not an Argentine citizen) has lived in Buenos Aires since 2021 on temporary residence and works for a local company. They became an Argentine tax resident after 12 months (ITL art. 116(b)). * In 2022 they bought an apartment in CABA for USD 180,000. * They sign the deed of sale on 16 November 2026 for USD 250,000 (ARS 390,975,000), paid in US dollar banknotes at the deed. * They leave Argentina on 15 December 2026 to return to their country of nationality. * Their other assets are a local bank account with ARS 15,639,000 (US$10,000) and a foreign brokerage account with USD 40,000 (ARS 62,556,000).

Step 1. Income tax on the gain. * The apartment was acquired after 1 January 2018, so it is an art. 99 property (Decree 862/2019 art. 255). * The sale is after 1 January 2026, so the result is exempt (ITL art. 26(n), second paragraph; Decree 406/2026). This holds whether the seller is resident or non resident on the deed date. * The gain of USD 70,000 is not taxed. Tax: ARS 0. * Before Law 27.802, the 15% rate of ITL art. 99 would have applied to price minus the CPI indexed peso cost. The reform makes that calculation unnecessary.

Step 2. Transfer taxes. * No ITI (repealed 8 July 2024) and no COTI (abrogated May 2025). * Stamp tax: the CABA rate is not in the sources. The Fiscal Consensus 2021 cap is 3.5%, so the maximum exposure is 3.5% × ARS 390,975,000 = ARS 13,684,125 (US$8,750). How it is shared between buyer and seller, and whether a housing exemption applies to the buyer, depends on CABA law. * Notary withholding: if the notary still applied the 3% RG 2139 withholding to a resident seller, the amount would be ARS 11,729,250 (US$7,500). It would then have to be recovered in the seller's return. The seller should ask the notary in advance how the exemption is documented (unconfirmed).

Step 3. FX: moving the USD 250,000. On 16 November 2026 the seller is still living and working in Buenos Aires, so they are an FX resident (point 6.5.1). * They deposit the banknotes in their own US dollar account. The bank will ask for the deed as proof of origin (unconfirmed). * On 17 November 2026 they order a transfer to their own account abroad under point 3.14.1. The bank registers it in the BCRA online system and the seller signs the 90 day undertaking not to buy securities settled in foreign currency until 15 February 2027. * No BCRA approval is needed. Banks may not charge a commission on incoming transfers to individuals' own accounts (point 2.8). The FX rules do not set the fee for outgoing transfers, which is at the bank's commercial discretion, charged as a separate item (point 3.14, last paragraph) (unconfirmed). * If the price had been paid in pesos, the seller would buy dollars under point 3.8 by debit to their account. There is no cap, and the deed is the evidence of assets (point 3.8.4). The transfer abroad follows the same day. * If the seller waited until after moving abroad, the bank might treat them as a non resident. Purchases of foreign currency would then need prior approval (point 3.13.1), and 3.14.1 transfers might be refused (unconfirmed).

Step 4. Tax residence and personal assets. * The seller leaves on 15 December 2026. * If they obtain no foreign permanent residence certificate (a citizen returning home usually does not), they lose Argentine tax residence only after 12 months abroad, with up to 90 days of visits allowed. The loss takes effect on 1 January 2028 (ITL art. 117; Decree 862/2019 art. 283), unless ARCA accepts other evidence (unconfirmed). * They are therefore an Argentine resident on 31 December 2026 and 31 December 2027. They must report worldwide assets for personal assets tax and worldwide income for 2027, with foreign tax credits under ITL arts. 164 onward (see /guide/taxes/individuals-and-personal-assets-tax/). * Personal assets at 31 December 2026. Assets: USD 250,000 from the sale now abroad (ARS 390,975,000) + USD 40,000 brokerage (ARS 62,556,000) + local account (ARS 15,639,000) = ARS 469,170,000 (US$300,000). Peso deposits in Argentine banks are exempt under the personal assets law (unconfirmed); on that assumption the base is ARS 453,531,000 (US$290,000). * The 2026 non taxable minimum is not in the sources. Illustration only, using the 2025 MNI of ARS 384,728,044.57: excess = ARS 68,802,955.43. Tax = ARS 68,443.52 + 0.75% × (68,802,955.43 minus 13,688,704.13) = ARS 68,443.52 + ARS 413,356.88 = ARS 481,800.40 (about US$308), using the unindexed 2026 brackets of art. 25(d) (unconfirmed). * If the seller had obtained a foreign permanent residence certificate in November 2026, the loss would take effect on 1 December 2026. At 31 December 2026 they would be a non resident with no Argentine assets left after closing the local account, so no personal assets tax would be due (Law 23.966 art. 26).

Step 5. ARCA exit. * When the residence loss is proven, the seller files the final return covering 1 January to the end of the month after the loss (ITL art. 119). * They request cancellation of the income tax registration with the RG 4236 evidence, with a sworn translation and apostille if the documents are foreign. * They keep the CUIT active through a representative if any Argentine assets or accounts remain (ARCA, "Residentes en el exterior").

Timeline.

Cost to do it: income tax ARS 0; stamp tax up to ARS 13,684,125 (US$8,750) at the cap (unconfirmed); notary and agent fees (unconfirmed); bank transfer charges; two more years of Argentine returns unless foreign permanent residence is documented. Elapsed time from deed to money abroad: 1 to 2 business days.

Example 3. Capital reduction versus waiting for profits (short)

Facts. A Spanish SA converted a USD 1,000,000 capital contribution (ARS 1,563,900,000) through the MLC on 2 June 2025 to its Argentine SA. The business needs only half the capital.

FX. The contribution was converted after 21 April 2025, so the 180 calendar day period ended on 29 November 2025. A reduction of ARS 781,950,000 (US$500,000) can be repatriated without prior approval under point 3.13.1.7(i), once: * the LGS and IGJ steps are complete; and * the peso liability to the shareholder is declared in the external survey (point 3.13.1, final paragraph).

Tax. If the reduction returns only paid in capital, none of it is a dividend under ITL art. 49, because the excess over computable cost is zero. Any part attributable to accumulated profits is a 7% dividend (art. 97). The Spain treaty may reduce that rate (see /guide/taxes/treaties/).

Timeline: * Week 1: special balance sheet and auditor report. * Week 2: meeting. * Weeks 2 and 3: 3 day publication, then a 15 day opposition window. * Weeks 5 to 10: IGJ registration (unconfirmed). * Then: FX access.

Cost to do it: publication, audit, notary and IGJ fees (unconfirmed); 2 to 4 months.

Practical traps

1. Taking pesos for a private sale. Point 3.13.1.10 works only through the buyer's access with new long term foreign financing. A foreign seller who accepts pesos has no clear listed exception and may need BCRA approval to get the money out.
2. Contributions not converted through the MLC. Points 3.13.1.7 and 3.13.1.13 require that the original funds were brought in and converted. Capital contributed in kind, by capitalising debt, or with pesos bought outside the MLC does not count. Keep the bank conversion certificates for every contribution.
3. Pre October 2020 capital. Point 3.13.1.7 starts on 2 October 2020. Older contributions have no time based exception.
4. The 2 year clock for 2020 to April 2025 money. Contributions converted in, say, March 2025 cannot be repatriated before March 2027.
5. Peso cost basis in a dollar world. The actual gain election indexes cost by CPI, not by the exchange rate. Compute both options before closing.
6. Withholding agent exposure. If the resident buyer fails to withhold, it bears the tax (ITL art. 102, last paragraph). Buyers should not pay the full gross price.
7. Cross restrictions after the deal. A resident buyer that accessed the MLC cannot, for 90 days afterwards, sell securities for foreign currency or buy CEDEARs (point 3.16.3.2). Group companies are included (point 3.16.3.4).
8. Foreign holdco deals. If the buyer buys the foreign parent and uses 3.13.1.10, it must redomicile the parent to Argentina within 12 months. Until then, no dividends may go to the foreign parent.
9. Leaving before converting. Individuals who move abroad before converting their pesos and transferring their dollars risk being treated as non residents. Do the FX steps first.
10. Residence does not end at the airport. Without a foreign permanent residence certificate, tax residence continues for 12 months. Personal assets tax on worldwide assets and income tax filings continue meanwhile.
11. Registrations stay open until cancelled. RG 4236 art. 2: all obligations continue until ARCA cancels the registration. Unfiled returns generate penalties (see /guide/taxes/procedure-audits-tax-court/).
12. Notary procedure after Decree 406/2026. The exemption is clear in the regulation, but the notary withholding procedure (RG 2139) may not have caught up. Ask the notary early.
13. BOPREAL is not cash. It converts trapped dividends into a long dated bond that pays in foreign currency. Price, liquidity and timing need checking before relying on it.
14. Cross reference error in point 3.16.3.5(iv). It still points to "3.13.1.12" for portfolio repatriation. Banks may ask for 3.16.3 statements anyway. Be ready to cite Com. A 8257.
15. Mandatory reduction status. If losses have consumed reserves and half the capital, art. 206 may force a reduction regardless of the exit plan, depending on whether the Law 27.541 suspension has lapsed (unconfirmed).

Recent changes

• 8 July 2024: ITI repealed (Law 27.743 art. 67). New personal assets scales for 2023 to 2027 (art. 63).
• 14 April 2025 (Com. A 8226): resident individuals can buy foreign currency for savings without cap or prior approval. Dividends from fiscal years starting 1 January 2025 or later may be paid without approval.
• 21 April 2025 (Com. A 8230): FDI repatriation after 180 days for new contributions. Portfolio repatriation route for funds converted from that date.
• 23 May 2025 (Com. A 8245): foreign currency applied directly to Treasury primary subscriptions counts for the portfolio route.
• 23 May 2025 (ARCA RG 5697/2025, BO): COTI regime abrogated.
• 13 June 2025 (Com. A 8257): 180 day minimum holding period for portfolio repatriation removed. Portfolio repatriations exempted from the 90 day cross restriction statements.
• 18 September 2025 (Com. A 8331): sale to resident route redrafted for all sectors, including acquisitions through a foreign holding company and natural resources concessions.
• 26 September 2025 (Com. A 8336): 90 day securities undertaking reinstated for all individuals buying savings and transferring abroad.
• 6 March 2026 (Law 27.802): exemption for individuals' real estate gains on sales from 1 January 2026. Exemption for housing rental income. Clarification on citizenship by investment and tax residence (ITL art. 116, last paragraphs).
• 9 April 2026 (Com. A 8417): new BCRA online system for individuals' own account transfers announced (pending activation).
• 13 May 2026 (IGJ RG 3/2026, BO): amendments to IGJ Norms arts. 111 to 113.
• 1 June 2026 (Decree 406/2026): real estate exemption expressly extended to individuals resident abroad.
• 14 September 2026 (Com. A 8481): current consolidated FX text.

Pending changes

• BOPREAL: which series are open and on what terms (unconfirmed).
• Com. A 8417 online system for own account transfers: activation date (unconfirmed).
• RG 2139 and notaries after the 2026 exemption (unconfirmed).
• Point 3.16.3.5(iv) cross reference (unconfirmed).
• RG 4227 status and codes: whether amended since 2018 (unconfirmed).
• Capital repatriation ceiling under 3.13.1.7 (dollar amount of the contribution or more) (unconfirmed).
• Non resident sellers' peso proceeds: no listed exception identified (unconfirmed).
• Art. 49 and SRL quota reductions (unconfirmed).
• Art. 206 suspension under Law 27.541 (unconfirmed).
• Loss of residence for nationals returning home without a "permanent residence" certificate (unconfirmed).
• Companies' savings purchases (point 3.10) remain under prior approval. No sourced timetable for lifting them.

FAQ

1. Can a foreign parent take its capital out of Argentina without BCRA approval? Yes, if the capital was brought in and converted through the MLC on or after 2 October 2020 and enough time has passed: 180 days for funds converted from 21 April 2025, or 2 years for funds converted from 2 October 2020 to 20 April 2025. The target must not control a local financial entity (point 3.13.1.7). If the money goes out by capital reduction, the LGS steps and the external survey declaration must be completed first (point 3.13.1, final paragraph).

2. What tax does a foreign company pay when it sells quotas of an Argentine SRL? 15% on a presumed gain of 90% of the price, which is 13.5% of the price. It may elect 15% on the actual gain, computed as price minus CPI indexed cost and expenses incurred in Argentina, if it gives the withholding agent the supporting documents (ITL arts. 98, 104(i); RG 4227 arts. 7 and 8). A tax treaty may reduce this. There is none with the United States in the sources.

3. Who withholds the tax on the share sale? The resident buyer (RG 4227 art. 6(a)). If the buyer is also foreign, the seller pays through its Argentine legal representative, or by international bank transfer in US dollars or euros by the 10th business day after the operation (ITL art. 98, last paragraph; RG 4227 arts. 6(d), 9(b)).

4. Can a local buyer buy dollars to pay a foreign seller? Only under point 3.13.1.10: simultaneously with new foreign financing that has an average life of at least 4 years and at least 3 years of grace, for at least 10% of the capital, and for a target that is not a financial entity. Otherwise BCRA prior approval is needed.

5. I invested in Argentine bonds as a non resident in 2025. Can I take the money out? Yes, if the investment was made with funds converted in the MLC from 21 April 2025 (or with foreign currency applied directly to Treasury primary subscriptions from 23 May 2025). A local bank must certify that, and the amount is limited to collections or sale proceeds (point 3.13.1.13). Since 13 June 2025 there is no minimum holding period (Com. A 8257). Gains on government bonds are exempt for foreign beneficiaries outside non cooperative jurisdictions (ITL art. 26(u)).

6. Do I pay income tax when I sell my apartment in Buenos Aires in 2026? If you are an individual and the apartment was acquired from 1 January 2018 (an art. 99 property), no: sales from 1 January 2026 are exempt for residents and non residents (ITL art. 26(n); Decree 406/2026). If it was acquired before 2018, the ITI that used to apply was repealed in July 2024. Provincial stamp tax and notary costs still apply (unconfirmed).

7. Can I send the sale proceeds abroad? If you are still an FX resident: yes. Deposit the dollars in your own local account and transfer them to your own foreign account under point 3.14.1, with BCRA online registration and a 90 day undertaking not to buy securities settled in foreign currency. If you are paid in pesos, you can buy dollars without a cap by debit to your account, with evidence of consistent assets (point 3.8). If you are already a non resident, buying dollars needs prior approval (point 3.13.1), and banks may not process 3.14.1 transfers (unconfirmed).

8. When do I stop being an Argentine tax resident? When you acquire permanent residence in another country, or after 12 months continuously abroad (visits of up to 90 days in each 12 months do not interrupt it). The loss takes effect on the first day of the following month (ITL art. 117; Decree 862/2019 art. 283). You must prove it to ARCA, or to the consulate if you are already abroad, and file for the part of the year (ITL art. 119; RG 4236 art. 2).

9. Do I still pay personal assets tax after leaving? For every 31 December on which you are still a resident, yes, on worldwide assets above the non taxable minimum: 0.50% to 0.75% for 2026 and 0.25% for 2027 (Law 23.966 art. 25). Once non resident, only Argentine assets are taxed, at 0.50% through the local holder, and quotas or shares through the company (arts. 25.1 and 26).

10. My company has old peso dividends it cannot pay abroad. What are the options? Dividends from fiscal years starting from 1 January 2025 can be paid without approval (point 3.4.4.1). Older profits can use the 30% of new FDI route (point 3.4.4.4) or BOPREAL. With BOPREAL, the company subscribes bonds for the pending dividends and waives other MLC access for that debt (point 4.6.1). A non resident who already collected peso dividends since 1 September 2019 can subscribe BOPREAL for up to that amount adjusted by CPI (point 4.6.2). See /guide/fx/dividends-profits/.

11. Does a capital reduction trigger dividend tax? Only the part that exceeds the computable cost of the shares, which is equity minus realised profits and the reserves that come from them, divided by the shares outstanding (ITL art. 49). That part is a dividend subject to 7% (art. 97). Application to SRL quotas is not expressly settled (unconfirmed).

12. How long do creditors have to object to a capital reduction? 15 days from the last of 3 days of publication (LGS arts. 83(3), 204). Objections do not stop the process, but the company should pay or secure opposing creditors. The IGJ requires the deed to list them and how they were treated (IGJ RG 15/2024 art. 98).

Primary sources

• BCRA, consolidated text "Exterior y Cambios", updated to 14 September 2026, last communication A 8481 (points 2.8, 3.4, 3.8, 3.9, 3.10, 3.13, 3.14, 3.16, 4.6, 6.5, 7.9. Issued with
• BCRA Com. A 8226 (11 April 2025)
• BCRA Com. A 8230 (16 April 2025), points 2 and 3
• BCRA Com. A 8245 (22 May 2025), point 2
• BCRA Com. A 8257 (12 June 2025), points 1 and 2 (downloaded for this page)
• BCRA Com. A 8307 (25 August 2025), consolidated text
• BCRA Com. A 8331 (18 September 2025)
• BCRA Com. A 8336 (26 September 2025)
• BCRA Com. A 8417 (9 April 2026)
• Income Tax Law, t.o. 2019 (Decree 824/2019), Infoleg updated text (arts. 15, 26(n), 26(u), 49, 97, 98, 99, 102 to 104, 116 to 123
• Decree 862/2019 (ITL regulation), updated text including Decree 406/2026 (unnumbered article after art. 83, arts. 249, 250, 252, 254 to 259, 281, 283, 284
• AFIP RG 4227/2018, BO 12 April 2018, arts. 5 to 10 and 13 (downloaded for this page)
• AFIP RG 4236/2018, BO 8 May 2018, arts. 1 to 3
• Law 27.802, BO 6 March 2026, arts. 192 and 194
• Law 27.743, BO 8 July 2024, arts. 63 and 67
• Law 23.966, Title VI (personal assets tax), Infoleg updated text (arts. 25, 25.1, 26
• Law 19.550 (LGS), t.o. 1984, Infoleg text (arts. 83, 152, 153, 160, 203 to 206
• IGJ RG 15/2024 (IGJ Norms), Infoleg text with later amendments noted (recital 37, arts. 97, 98, 115, 235
• Law 27.687 (Fiscal Consensus 2021), clause THIRD (c)
• ARCA, "CUIT y CDI, Residentes en el exterior"
• ARCA RG 5697/2025
• AFIP RG 2139/2006, updated text (as summarised in /guide/real-estate/foreign-ownership/

Related pages

• How do I take money out of Argentina after selling property?
• Dissolving and liquidating a company in Argentina
• Insolvency in Argentina: concurso preventivo, APE and quiebra
• Selling shares in an Argentine company as a foreign seller: capital gains tax, withholding, payment via ARCA, registration and repatriating the proceeds
• How long does it take to close a company in Argentina?