Can an Argentine company pay dividends abroad?

Last verified: 26 Oct 2026 · Status: Changing

Short answer. Yes. Profits from fiscal years that started on or after 1 January 2025 can be sent abroad through the official FX market without BCRA approval, if they come from audited annual statements approved by the shareholders. The company withholds 7% income tax first. Older retained earnings still need BCRA approval, BOPREAL bonds or another narrow route.

As of 26 Oct 2026. Rules in force at that date.

Key rules

Corporate law. A dividend may only come from realised and liquid profits in a balance sheet approved by the shareholders (Law 19.550, arts. 68 and 224). Prior losses are covered first and the legal reserve topped up (arts. 70 and 71).
Tax. On dividends paid abroad, the payer withholds 7% and pays it to ARCA as a single and final payment (Income Tax Law, t.o. 2019, art. 97, first and fourth paragraphs; rate set by Law 27.630, art. 7). A 35% "equalisation" withholding on dividends above accumulated taxable income (art. 74) applies only to profits of fiscal years that started before 1 January 2018 (Law 27.430, art. 83). Treaty caps are mostly 10% or 15% (for example Spain treaty, art. 10(2)), so they rarely lower the 7%; the one exception found is Qatar's 5% where the Qatari State is the beneficial owner (art. 10(2)). There is no US treaty.
Exchange controls. Under point 3.4 of the BCRA text "Exterior y Cambios" (Com. A 8481, updated to 14 September 2026), a bank may sell dollars for dividends to non resident shareholders if the balance sheets are closed and audited (3.4.1), payments stay within the peso amount the meeting allocated to them, under sworn statement (3.4.2), the last due BCRA external assets and liabilities survey is filed (3.4.3), and a route in 3.4.4 fits. The main route, 3.4.4.1, covers profits in audited annual statements of fiscal years started on or after 1 January 2025, from Com. A 8226, point 6 (11 April 2025, in force 14 April 2025).
Older profits. Pre 2025 profits need another route: up to 30% of new foreign direct investment converted through the FX market since 17 January 2020 (3.4.4.4, with the converting bank's certificate, a 30 day wait and proof of capitalisation); or BCRA prior approval (closing paragraph of 3.4); or a subscription of BOPREAL bonds for the pending peso amount (point 4.6.1, from Com. A 7999). Taking BOPREAL waives FX market access for that dividend except via the bonds' dollar payments (4.6.1.4).
Sworn statements for every payment. The company signs the point 3.16 statements, including that it gave no pesos to its controller or group companies in the previous 90 days (3.16.3.4).

What changes the answer

Fiscal year start date. A 30 June year end company qualifies only from the year started 1 July 2025.
Profits from 2024 or earlier. Then you need the 30% FDI route, BOPREAL or prior approval. BCRA has no published deadline for approvals, and no rule schedules release of these profits.
Pre 2018 profits. No 7% to the extent they were taxed at 35% (ITL art. 193; Decree 862/2019, art. 119), but the 35% equalisation tax may apply; oldest profits are presumed paid first.
SRL or branch. Point 3.4 speaks of "accionistas" and their "asamblea", not SRL partners or branch head offices; confirm with the bank before filing (BCRA has not published a criterion).

Worked examples

Facts. A Spanish company owns 100% of an Argentine SAU (calendar year, audited 2025 statements, legal reserve full, no prior losses). On 23 October 2026 the shareholder resolves a dividend of ARS 100,000,000 out of 2025 profits. Dollar figures use dólar MEP ARS 1,563.90 per US$ on 23 Oct 2026, the dólar MEP selling rate (dolarapi.com) that day (live rate: /data/mep/). The company really buys at the price agreed with its bank (point 1.3).

Step or item	Time	Cost ARS	Cost USD (MEP, 23 Oct 2026)
1. Audit and approval of 2025 statements; dividend resolution in pesos	Meeting within 4 months of year end (Law 19.550, art. 234)	Audit fee (not set in an official source)	n/a
2. Gross dividend approved	Approval date	100,000,000	63,942.71
3. 7% withholding deposited with ARCA (ITL art. 97)	When paid or made available (not set in an official source)	7,000,000	4,475.99
4. Net pesos converted at the bank (point 3.4.4.1)	Same day once the bank checks the file	93,000,000	59,466.72
5. Wired to the Spanish parent	Same day or next	Bank fees, not in sources	about 59,467 at MEP

Step by step.

Fiscal year 2025 started on 1 January 2025: point 3.4.4.1 applies, no BCRA approval.
Withholding: 100,000,000 × 7% = ARS 7,000,000. The Spain cap is higher, so 7% stands; no equalisation tax on post 2018 profits (Law 27.430, art. 83).
Net: 100,000,000 − 7,000,000 = ARS 93,000,000.
In dollars at MEP: 93,000,000 ÷ 1,563.90 = US$ 59,466.72. At that day's BCRA Com. A 3500 wholesale rate (ARS 1,528.263) they buy US$ 60,853.40, US$ 1,386.68 more. The bank's agreed price on the day decides.
Ceiling check: ARS 93,000,000 transferred plus ARS 7,000,000 withheld equals the ARS 100,000,000 allocated (point 3.4.2).

Cost to do it: 7% tax plus audit and bank fees (not in official sources); no BCRA fee; no capital beyond the gross pesos. Time: up to four months from year end to meeting, then days at the bank.

Practical traps

Paying pesos locally to the parent. A peso dividend credited locally to the controlling shareholder blocks the company's FX market access for 90 days, imports and debt included (point 3.16.3.4).
Missed survey filing. An overdue BCRA external assets and liabilities return stops the transfer (point 3.4.3). Smaller declarants now file yearly within 90 days of year end (Com. A 8304).
Interim dividends. Point 3.4.4.1 refers to annual statements. Whether interim dividends (lawful only for art. 299 companies, Law 19.550 art. 224) can use it is not stated in point 3.4, so ask the bank first.

FAQ

Does a small company need an audit? Yes, for the official FX route (point 3.4.1).

Is the 7% creditable at home? It is a final Argentine tax (ITL art. 97); any credit depends on the parent's home country law.

Can we still use BOPREAL for 2024 profits? Point 4.6.1 still allows it. Whether a series is open in October 2026, and on what terms, was not confirmed in an official source, so ask your bank. Series 4 (Com. A 8233) matures no later than 31 October 2028.

Does the company also pay tax on the shareholder's shares? Yes, 0.50% a year of the shares' equity value (personal assets tax), recoverable from the shareholder (Law 23.966, article after art. 25).