Federalism and tax sharing in Argentina: coparticipación explained

Last verified: 27 Oct 2026 · Status: Changing

Argentina is a federation of 23 provinces plus the autonomous City of Buenos Aires (CABA). The Nation collects the big taxes (VAT, income tax, excise, the bank debit and credit tax), and shares most of them with the provinces under a system called coparticipación federal de impuestos. Provinces collect their own taxes, above all gross income tax (ingresos brutos), which in 2025 produced 78.9% of all provincial own tax revenue (DNAP, TOP 2025).
The law in force is Law 23.548 of 1988, a "transitional" regime (art. 1) that renews itself automatically while no replacement exists (art. 15). The 1994 Constitution ordered a new ley convenio by the end of 1996 (art. 75(2) and Sixth transitional clause). No new law has been passed in the 30 years since; Law 23.548 is still the law that the 2026 decrees and the Budget Law refer to.
Statutory split (Law 23.548 art. 3): Nation 42.34%, provinces 54.66%, a 2% "recovery" fund for four provinces, and 1% for a discretionary fund, the ATN (Aportes del Tesoro Nacional). As actually applied by the Ministry of Economy today, after carving out the CABA and Tierra del Fuego from the Nation's share, the split is Nation 40.24%, CABA 1.40%, provinces including Tierra del Fuego 57.36%, ATN 1% (MECON distribution scheme 2021 to present).
The split among provinces (art. 4) is a fixed list of percentages agreed in 1987/1988, not a formula. Buenos Aires province gets 19.93% of the provincial pool (plus most of the 2% recovery fund); the smallest shares are 1.38% (Chubut and Santa Cruz).
Fiscal pacts have repeatedly patched the system: 1992 (15% of the shared pool diverted to the national pension system), 1993 (provinces promised to cut distortive taxes), 2002 (end of guarantees, debt swap), 2016 (gradual end of the 15% diversion after 2015 Supreme Court rulings), 2017 (Consenso Fiscal: tax caps, end of the Buenos Aires suburban fund, compensations), and 2021 (Consenso Fiscal replacing the earlier tax commitments).
The CABA dispute: the City's share has been fixed by presidential decree (1.40% in 2003, 3.75% in 2016, 3.50% in 2018, 2.32% then 1.40% in 2020). In December 2022 the Supreme Court ordered, as an interim measure, that the City receive 2.95% while the case continues (CSJ 1865/2020, 21 December 2022). As of the sources reviewed, there is no final judgment.
Discretionary money: the ATN fund is allocated by the national executive (art. 5). Congress passed a bill in 2025 to distribute it automatically; the executive vetoed it in full (Decree 652/2025). Since 2025 the Nation has also used cash advances against future coparticipación, for example up to ARS 400 billion each to several provinces in 2026 at a fixed 15% annual rate, repaid by automatic retention.
Why investors care: provincial dependence on transfers drives provincial tax pressure (gross income tax, stamp tax), the risk of new local levies, the credit quality of provincial bonds (which are often serviced from coparticipación), and whether a province has adhered to the RIGI stability regime. Law 23.548 art. 9(b) (no local taxes "analogous" to shared national taxes) is a legal defence for taxpayers, enforced by the Federal Tax Commission and the courts.

Peso amounts are converted at the dólar MEP (bolsa) selling rate of ARS 1,563.90 per US$ on 23 Oct 2026 (source: dolarapi.com, MEP quote). Conversions are indicative and move daily.

Key rules

1. The constitutional frame

Who may tax what. Congress may impose indirect taxes concurrently with the provinces, and direct taxes only "for a fixed time" and when defence, common security and general welfare require (Constitution art. 75(2), first paragraph). In practice, income tax and personal assets tax are national "direct" taxes renewed by law for fixed periods. Import and export duties belong exclusively to the Nation (art. 75(1)).
Sharing is mandatory. All taxes under art. 75(2) "are coparticipable", except the part or total that has a specific earmark (art. 75(2), first paragraph).
The ley convenio. A ley convenio, "on the basis of agreements between the Nation and the provinces", must set up the sharing regimes, guaranteeing automatic remittance of funds. Distribution among the Nation, the provinces and the CABA must be "in direct relation to the competences, services and functions of each", use objective criteria, and be "equitable, solidary", giving priority to an equivalent degree of development across the country. The law must start in the Senate, be passed by an absolute majority of all members of each chamber, may not be amended unilaterally or regulated, and must be approved by the provinces (art. 75(2), second to fourth paragraphs).
No transfer of functions without money. Competences, services or functions may not be transferred without reallocation of resources approved by Congress where needed and by the province or the CABA concerned (art. 75(2), fifth paragraph). This sentence is at the heart of the CABA litigation.
A federal fiscal body must control and supervise the system, with all provinces and the CABA represented (art. 75(2), sixth paragraph). In practice the Federal Tax Commission created under the old law continues (Law 23.548 art. 10) (unconfirmed).
Earmarks. Congress may create or change earmarks of shared resources, for a fixed time, by special law passed by an absolute majority of all members of each chamber (art. 75(3)).
Subsidies. Congress may grant Treasury subsidies to provinces whose revenues do not cover their ordinary expenses (art. 75(9)).
The deadline that was missed. The Sixth transitional clause required the coparticipation regime and the rules of the federal fiscal body to be set up "before the end of the year 1996". Until then, the distribution of competences may not be changed without the approval of the province concerned, and the distribution of resources in force at the 1994 reform may not be changed "to the detriment of the provinces".
Residual powers. Provinces keep all powers not delegated to the federal government (art. 121) and hold original ownership of the natural resources in their territory (art. 124), which is why oil, gas and mining royalties are provincial revenue.
The Supreme Court's view. In the CABA case the Court said that the new law, which should have been passed before the end of 1996, has not been agreed, and that the City is therefore unable to occupy the place the Constitution gives it (CSJN, CSJ 1865/2020, 21 December 2022, SAIJ summary SUA0083338). The national executive itself, in 2025, quoted an earlier ruling (Fallos 338:1356) calling on the executive and Congress to propose "the long delayed" coparticipation system (Decree 652/2025, recitals).

2. Law 23.548: the regime in force

Status and duration. Law 23.548 was sanctioned on 7 January 1988, promulgated on 22 January 1988 and published on 26 January 1988 (Infoleg record). It sets a "Transitional Distribution Regime" from 1 January 1988 (art. 1). It was to run until 31 December 1989 but "will be extended automatically in the absence of a substitute regime" (art. 15). That is why a 1988 transitional law still governs in 2026.

What is shared (the masa coparticipable), art. 2. All existing or future national taxes, except: (a) import and export duties; (b) taxes with their own special sharing regime; (c) earmarked taxes in force in 1988; and (d) taxes earmarked by a law of Congress with provincial adhesion for investments, works or activities of national interest, for a limited time. Fuel taxes are shared to the extent they exceed the amount credited to the Fuel Fund. An Infoleg note records that, since 1 April 1992, the costs of collecting the taxes are deducted before distribution (Decree 559/1992 art. 1, as noted under art. 2).

Primary distribution, art. 3. Of the total collected under the law:

(a) 42.34% automatically to the Nation;
(b) 54.66% automatically to the adhering provinces as a group;
(c) 2% automatically "for the recovery of the relative level" of four provinces: Buenos Aires 1.5701%, Chubut 0.1433%, Neuquén 0.1433%, Santa Cruz 0.1433%;
(d) 1% to the ATN fund (Fondo de Aportes del Tesoro Nacional a las provincias).

Secondary distribution, art. 4. The 54.66% is split among provinces by fixed percentages (Table 2 below). The list has 22 provinces. The CABA and Tierra del Fuego are not in it; they are paid from the Nation's share (art. 8, see below).

ATN fund, art. 5. The fund is for "emergency situations and financial imbalances" of provincial governments. It is budgeted under the Interior ministry, which assigns it and must report quarterly to the provinces on the distribution and the criteria used. The national executive may not send provinces sums above the 1% in addition to the shares of the law, except under other special regimes or specific budget credits. The 2025 veto decree states that the ATN now sits with the Vicejefatura de Gabinete del Interior under the Chief of Cabinet (Decree 652/2025, recitals).

Automatic and daily, art. 6. Banco de la Nación Argentina transfers each province's and the ATN fund's share automatically and daily, free of charge.

Floor, art. 7. The amount distributed to provinces may not be less than 34% of national tax revenue of the central administration, shareable or not. The national accounting office checks this by 15 February of the following year, and any shortfall must be paid by 30 April (art. 20).

CABA and Tierra del Fuego, art. 8. From its own share the Nation gives the (then) Municipality of the City of Buenos Aires and the (then) National Territory of Tierra del Fuego a participation "compatible with historical levels", not less in constant terms than the sum transferred in 1987. Tierra del Fuego became a province by Law 23.775; its coefficient was set at 0.388% (Decree 2456/1990) and raised to 0.70% (Decree 702/1999, BO 7 July 1999). The CABA coefficient is discussed in section 5.

Province obligations on adhesion, art. 9. A province joins by passing a law that:

(a) accepts the regime "without limitations or reservations";
(b) undertakes that neither the province nor its municipalities or agencies will apply local taxes analogous to the shared national taxes, by any name (taxes, fees, contributions), nor tax raw materials used in products subject to the shared taxes. Fees for services actually rendered are not covered by the ban. Excise goods may not bear a proportionally higher local burden than similar goods (with an exception for retail sale of wine and alcoholic drinks). The ban expressly excludes provincial taxes on real estate, gross income, motor vehicles, stamps and free transfers of property, and taxes or fees in force at 31 December 1984 earmarked for works. Art. 9(b)(1) then sets the basic design of gross income tax and art. 9(b)(2) that of stamp tax (both are summarised on the gross income tax page);
(c) undertakes not to tax foodstuffs in their natural or manufactured state;
(d) keeps applying the Convenio Multilateral of 18 August 1977;
(e) repeals provincial taxes, and promotes repeal of municipal ones, that conflict with the law, with suspension within 10 calendar days of notice of a decision declaring the conflict;
(f) suspends the participation of non compliant municipalities in national and provincial taxes;
(g) sets up a provincial sharing system for its municipalities with objective indices and automatic remittance every fortnight.

Federal Tax Commission (Comisión Federal de Impuestos, CFI), arts. 10 to 14. One representative of the Nation and one of each adhering province (art. 10, as amended by Law 25.049, BO 14 December 1998). Its functions include approving the distribution percentages, controlling the settlements, and deciding, on its own motion or on request of the Nation, provinces, municipalities, taxpayers or recognised associations, whether national or local taxes conflict with the law (art. 11(a) to (d)). Decisions bind the Nation and the provinces, subject to a review request within 60 calendar days, then only the federal extraordinary appeal to the Supreme Court, which does not suspend the decision (art. 12). A jurisdiction must report compliance within 90 days (or 60 after a review); otherwise the Commission may order Banco Nación to withhold the transfers of the national tax analogous to the challenged levy (art. 13). Taxpayers may claim refunds of a levy declared in conflict directly before the local tax authority, without going first to the Commission (art. 14).

Late adhesion, art. 16. A province that had not communicated adhesion within 180 days was considered not adhered; later adhesions count only from receipt of the adhesion norm.

3. How the shared pool is actually built in 2026

The statutory percentages are only the start. The Ministry of Economy publishes an official "scheme of financing and distribution of national resources" for 2021 to the present. Read with the laws it cites, it shows the following.

Deduction for the tax agency. A percentage for the financial autonomy of the tax agency (AFIP, now ARCA), 1.9% of tax and customs revenue, is deducted from each tax before the pool and the special regimes are formed. The scheme notes that La Pampa and Santa Fe do not contribute "by application of the CSJN ruling" (MECON scheme, note 1) (unconfirmed).
What feeds the gross pool. VAT 89%; income tax 100%; excise 100% (except insurance); minimum presumed income tax 100%; interest paid tax 100%; "others" 100% (including the gambling prize tax at 80.645%); and the cooperative capital tax 50% (MECON scheme). Income tax is now shared 100% because the earlier earmarks in former art. 104 of the Income Tax Law were repealed under Consenso Fiscal 2017 (Law 27.429, Annex, clause I(b)).
VAT. By law 11% of VAT goes to the national pension system and 89% is distributed under Law 23.548 (VAT Law art. 52). Within the 11%, the law sets 90% for the national system and 10% for provincial pension funds by number of beneficiaries at 31 May 1991 (art. 52(a)). The Ministry scheme shows the 11% split as 93.7% national and 6.3% provincial and municipal pension funds (unconfirmed).
Fixed deductions. Before the net pool, a provincial "Fiscal Imbalance Compensation Fund" of ARS 549.6 million a year is deducted, and from the provincial share ARS 1,284.2 million a year for transferred services (MECON scheme). These are nominal amounts and are now immaterial relative to monthly flows (for comparison, the provinces received ARS 6,457,628 million of coparticipación in September 2026 alone, DNAP RON).
Primary split as applied: ATN 1%; National Treasury 40.24%; CABA 1.40%; provinces including Tierra del Fuego 57.36% (MECON scheme). The arithmetic matches the law: 42.34% less CABA 1.40% less Tierra del Fuego 0.70% = 40.24%; 54.66% plus 2% plus 0.70% = 57.36%. Note that the scheme still shows 1.40% for the CABA, not the 2.95% ordered by the Supreme Court in 2022 (section 5).
Education earmark. After the secondary split, part of each province's share is earmarked for education under Law 26.075 art. 7 (created in 2006 for five years). It has been extended year by year; for 2026 by the Budget Law (Law 27.798 art. 13). In the Ministry's daily data the provincial coparticipación column is shown "net of Law 26.075" with the education amount in a separate column. In September 2026 the education column was ARS 1,021,615 million of a gross provincial total of ARS 6,457,628 million, about 15.8% (DNAP RON, September 2026).
Other national taxes with their own sharing rules (MECON scheme): personal assets tax (after a small deduction, 93.7% under Law 23.548 percentages with 41.64% to the Treasury, 1% ATN and 57.36% to provinces, and 6.3% to provincial pension funds); the simplified regime for small taxpayers (Monotributo), 70% to national social security and 30% to provinces under Law 23.548 (Law 24.977 art. 59(a) as cited in the scheme); fuel taxes, with fixed percentages to the Treasury, ANSES, FONAVI housing fund, provinces and trust funds (Law 23.966 as amended by Law 27.430); and the bank debit and credit tax, 100% to national social security (Law 25.413 as modified by Law 27.432, per the scheme). Export and import duties are not shared at all (Law 23.548 art. 2(a)).

4. The fiscal pacts, one by one

Pact	Signed	Approved by	What it did to coparticipación
Acuerdo entre el Gobierno Nacional y los Gobiernos Provinciales ("Pacto Fiscal I")	12 Aug 1992	Law 24.130 (sanctioned 2 Sep 1992; BO 22 Sep 1992)	From 1 Sep 1992 the Nation may retain 15% of the pool plus ARS 43.8 million a month to pay national pensions and to cover provincial imbalances (clause 1); guaranteed provinces a minimum of ARS 725 million a month until 31 Dec 1993 (clause 3); Nation not to deduct further amounts or transfer new services without provincial consent (clause 6). Law 24.130 art. 2 suspended Law 23.548 to the extent it opposed the agreement.
Pacto Federal para el Empleo, la Producción y el Crecimiento ("Pacto Fiscal II")	12 Aug 1993	Decree 14/1994 (BO 25 Jan 1994), authorised by Law 24.307 art. 33; extended by Law 24.699 (BO 27 Sep 1996)	Provinces committed to repeal stamp tax, specific taxes on fuel, gas, electricity and sanitation, payroll taxes, and to exempt primary production, industry, construction and financial services from gross income tax, and to cap property tax rates (clause 1); the Nation suspended retention of excess coparticipación above the ARS 725 million guarantee (clause 2(8)) and extended the 1992 agreement to 30 Jun 1995 (clause 3). Many commitments were later postponed.
Acuerdo Nación Provincias sobre Relación Financiera y Bases de un Régimen de Coparticipación	27 Feb 2002	Law 25.570 (sanctioned 10 Apr 2002; BO 6 May 2002)	30% of the bank debit and credit tax added to the pool (art. 1); all guarantees on transfer levels cancelled (art. 4; law art. 2); parties committed to pass a full coparticipation law by 31 Dec 2002 with a federal fiscal body and a countercyclical fund (art. 7); provincial debt converted into national debt, guaranteed with coparticipación (art. 8). The 2026 Budget still pays art. 11 obligations to five provinces (Law 27.798 art. 14).
Agreement of 23 May 2016 (and with Santiago del Estero, 26 May 2016)	2016	Law 27.260 arts. 24 to 26 (BO 22 Jul 2016)	Gradual end of the 15% retention of 1992: 12 points in 2016, 9 in 2017, 6 in 2018, 3 in 2019, zero from 2020 (Annex II, art. 1, Santiago del Estero text; the general Annex I is cited in Consenso 2017 recitals). Treasury to cover the gap for the pension system (art. 26).
Consenso Fiscal 2017	16 Nov 2017	Law 27.429 (sanctioned 21 Dec 2017; BO 2 Jan 2018)	Repeal of Income Tax Law former art. 104 earmarks from 1 Jan 2018 (clause I(b)); compensations to provinces and to Buenos Aires province for the suburban fund, ARS 21,000 million for 2018 and ARS 44,000 million for 2019, updated by inflation (clause II(a), (d), (e), (f)); bond for provinces other than Buenos Aires (II(c)); reduction of the CABA coefficient (II(g)); gross income and stamp tax caps (III); provinces to drop more than 50 lawsuits over coparticipación (III(t), (u)); commitment to a new coparticipation law (I(m)).
Consensos 2018, 2019, 2020	13 Sep 2018; 17 Dec 2019; 4 Dec 2020	Laws 27.469 (BO 4 Dec 2018), 27.542 (BO 12 Feb 2020), 27.634 (BO 7 Jul 2021)	Postponed and suspended the 2017 tax commitments (details on the gross income tax page).
Consenso Fiscal 2021	27 Dec 2021	Law 27.687 (sanctioned 15 Sep 2022; BO 4 Oct 2022)	Replaced the provincial tax commitments of the 2017 to 2020 pacts (clause 16); new gross income tax rules and caps (clause 2); one year limit on new foreign currency provincial debt (clause 8); one year suspension of provincial lawsuits on coparticipación (clause 13); pending 2017 compensations paid in 12 instalments from January 2022 (clause 14).

The 2015 rulings and the end of the 15%. On 24 November 2015 the Supreme Court ruled in the cases brought by Santa Fe, San Luis and Córdoba against the 15% retention (as cited in DNU 2635/2015, recitals). DNU 2635/2015 (BO 1 Dec 2015) ordered the retention to stop for all jurisdictions; it was repealed by DNU 73/2016 (BO 13 Jan 2016) (Infoleg links). The phase out was then agreed in 2016 and ratified by Law 27.260 (unconfirmed).

5. The CABA share and the Supreme Court

Period	Coefficient for the CABA (of the Law 23.548 total)	Norm
1988 to 2002	Not a fixed percentage; "compatible with historical levels", not below 1987 in constant terms	Law 23.548 art. 8
From 26 Apr 2002	Daily automatic transfer up to 1/12 of the annual budget amount	Decree 692/2002 (BO 30 Apr 2002)
From 1 Jan 2003	1.40%	Decree 705/2003 (BO 27 Mar 2003), after an agreement of 12 Dec 2002 approved by CABA Law 1008
From 1 Jan 2016	3.75%, the difference over 1.40% to fund the security functions transferred to the City in January 2016	Decree 194/2016 (BO 19 Jan 2016); Decree 399/2016 (BO 25 Feb 2016)
From 1 Jan 2018	3.50% (reduction agreed in Consenso 2017 clause II(g))	Decree 257/2018 (BO 3 Apr 2018)
From 10 Sep 2020	2.32% until Congress approves the security transfer; then 1.40%. Difference to a new fund for Buenos Aires province	Decree 735/2020 (BO 10 Sep 2020), which repealed Decrees 194/2016, 399/2016 and 257/2018
From 28 Dec 2020	1.40% under art. 8, plus a separate monthly transfer for security costs (1/12 of ARS 24,500 million, updated quarterly)	Law 27.606 (sanctioned 10 Dec 2020; BO 28 Dec 2020) arts. 3 and 4
From 21 Dec 2022, while the case lasts	2.95%, daily and automatic through Banco Nación; Nation not to apply Law 27.606	CSJN interim order, CSJ 1865/2020

The case. The City sued the Nation in the Supreme Court's original jurisdiction, asking it to declare Law 27.606 unconstitutional because it reduced the City's coefficient unilaterally after the security functions had been transferred by agreement, and to recover the funds withheld (CSJ 1865/2020, ruling of 21 December 2022, recital 1). The Court had already accepted original jurisdiction (20 April 2021, Fallos 344:660, as cited in the ruling of 12 August 2021) and ordered a parallel amparo against Decree 735/2020 to proceed as an ordinary action (CSJ 1141/2020, 12 August 2021).

The interim order of 21 December 2022. The Court ordered that, during the case, the Nation pay the City 2.95% of the pool defined in Law 23.548 art. 2, daily and automatically through Banco Nación, and abstain from applying Law 27.606. Its reasons, as summarised by SAIJ: (i) art. 75(2) makes the transfer of functions and the matching resources a concerted process, so the Nation may not reduce unilaterally after the fact the resources committed to a function already transferred; (ii) neither Decree 735/2020 nor Law 27.606 was approved by the City; (iii) there was urgency because the cut was abrupt and budgets are annual; (iv) the 2.95% splits the risk between the parties until the final ruling. The Court stressed that the City's share comes only from the Nation's share, so the provinces' shares are not affected whatever the result (recital 10).

What happened next. On 26 December 2022 the Chief of Cabinet ordered the Ministry of Economy to transfer to Banco Nación ARS 98,500 million in TX31 Treasury bonds, roughly 90 days of the difference between 1.40% and 2.95%, to be delivered daily to a City account, stating that no budget item covered the payment and that the Treasury would seek reconsideration (Decision 1282/2022, BO 27 Dec 2022). On 30 November 2023 the Court rejected the Nation's requests that the judges excuse themselves or be recused (CSJ 1865/2020, ruling of 30 November 2023). The 2026 daily transfer data show that the City's automatic coparticipación in September 2026 corresponds to 1.40%, not 2.95% (see Example 4) (unconfirmed).

Related change in 2024. Decree 192/2024 (BO 26 Feb 2024) repealed art. 4 of Decree 735/2020, which had created the Fund for the Fiscal Strengthening of Buenos Aires Province financed with the money taken from the City.

6. Discretionary transfers: the ATN, advances and other channels

ATN. 1% of the pool (Law 23.548 art. 3(d)), assigned at the discretion of the national executive for emergencies and imbalances (art. 5). The national government defended this discretion in 2025, saying that ATN were used in 2024 and 2025 for "water, economic, climate and food emergencies" (Decree 652/2025, recitals) (unconfirmed).
The 2025 ATN bill and veto. Congress passed bill 27.794 on 20 August 2025 to redistribute the ATN fund daily and automatically under arts. 3 and 4 of Law 23.548 (including the CABA and Tierra del Fuego shares), treating it as part of the shared pool. The executive vetoed it in full on 11 September 2025, arguing that the fund's purpose is discretionary emergency aid and that any change to the regime must be agreed by all jurisdictions (Decree 652/2025, BO 12 Sep 2025). Infoleg shows no Law 27.794 in force (unconfirmed).
Cash advances (anticipos financieros) against coparticipación. The Ministry of Economy may advance funds to a province that must be repaid within the same fiscal year by automatic retention of its Law 23.548 share and other unearmarked shared resources:

Decree (BO)	Province(s)	Maximum	Interest
190/2025 (17 Mar 2025)	Chaco	ARS 120,000 million (US$ 76.7 million)	TAMAR wholesale rate
922/2025 (29 Dec 2025)	Entre Ríos, for fiscal 2026	ARS 220,000 million (US$ 140.7 million)	TAMAR
161/2026 (19 Mar 2026)	Santa Cruz	ARS 100,000 million (US$ 63.9 million)	15% fixed nominal annual
219/2026 (6 Apr 2026)	Catamarca, Chaco, Chubut, Corrientes, La Rioja, Mendoza, Misiones, Río Negro, Salta, Santa Cruz, Tierra del Fuego, Tucumán	Up to ARS 400,000 million (US$ 255.8 million) each, set by the Treasury "according to repayment capacity"	15% fixed nominal annual
474/2026 (18 Jun 2026)	Entre Ríos (extension), Jujuy, Santa Fe	Up to ARS 400,000 million each	15% fixed nominal annual
584/2026 (13 Jul 2026)	Córdoba	Up to ARS 400,000 million	15% fixed nominal annual

In each case the province must assign its coparticipación as security and authorise the Treasury to retain it automatically (for example Decree 219/2026 art. 4; Decree 584/2026 art. 5) (unconfirmed). * Other budget transfers. Provinces also receive current and capital transfers outside the automatic regimes. In the consolidated provincial accounts, current transfers received fell from ARS 1,646,431 million in 2023 to ARS 1,610,350 million in 2024 (about 55% less in real terms using December to December inflation of 117.8%), and capital transfers from ARS 563,232 million to ARS 211,329 million (about 83% less in real terms). In 2025 both rose again (current ARS 3,231,826 million, capital ARS 391,237 million), about 53% and 41% in real terms with December inflation of 31.5% (DNAP APNF series; BCRA series 28; calculations in the source folder) (unconfirmed). * Retention fights. In February 2024 a federal court granted Chubut an urgent measure ordering the Nation to stop retaining coparticipación to repay loans from the Provincial Development Trust Fund until the debt was refinanced, within that fiscal year (Provincia del Chubut c/ Estado Nacional s/ medida autosatisfactiva, 27 February 2024, SAIJ summaries QG000051 to QG000053) (unconfirmed).

7. Provincial own taxes and their weight

Allowed taxes. Law 23.548 art. 9(b) lets provinces keep taxes on real estate, gross income, motor vehicles, stamps and free transfers. Gross income tax follows the design of art. 9(b)(1) and the Convenio Multilateral (art. 9(d)); stamp tax that of art. 9(b)(2). Rate caps and the taxable event as agreed in the fiscal pacts are on the gross income tax page.
Weight in 2025. Provincial own tax revenue of the 24 jurisdictions (La Pampa missing) was ARS 41,711,426 million (US$ 26.7 billion). Gross income tax was ARS 32,905,777 million, 78.9%; stamp tax 9.5%; real estate tax 5.7%; motor vehicles 4.1%; others 1.7% (DNAP TOP, cumulative to Q4 2025). Some provinces show zero real estate or vehicle tax because the tax is municipal or is not reported by the province (unconfirmed).
Own taxes versus transfers. In 2025 own taxes were 31.8% of total provincial revenue, national tax resources (coparticipación and special regimes) 45.3%, royalties 2.8% and transfers 2.8% (DNAP APNF consolidated). The average hides huge differences: own taxes were 74.1% of revenue in the CABA and 40.7% in Buenos Aires province, but 5.9% in Formosa and 7.5% in Santiago del Estero (Example 2).

8. Provincial debt and bonds

Authorisation. Provinces, the CABA and municipalities that adhere to the Federal Fiscal Responsibility Regime must send their debt and guarantee operations to the Interior and Economy ministries for authorisation (Law 25.917 art. 25, as replaced by Law 27.428 art. 17, in force from 1 January 2018).
Peso bonds and indexation. For 2026 the Budget Law exempts from the indexation ban of Law 23.928 (arts. 7 and 10) peso loans and peso bonds of provinces and the CABA used for infrastructure or debt restructuring, if authorised under Law 25.917 art. 25 where applicable (Law 27.798 art. 62).
Coparticipación as collateral. The 2002 agreement allowed provincial debt converted into national bonds to be guaranteed with coparticipación (Law 25.570, Annex, art. 8); the 2025 and 2026 advances are repaid by automatic retention (section 6). Provincial bond indentures commonly assign coparticipación flows as security (unconfirmed).
Consenso 2021. For one year from 31 December 2021, provinces could increase foreign currency debt only in listed cases, and the Nation was to deny authorisation to operations outside those rules (clauses 8 to 11). These limits were for one year only (unconfirmed).

9. RIGI and provincial adhesion

The RIGI declares qualifying large investments to be of national interest, and any rule or de facto measure of the Nation, an adhering province, its municipalities or the CABA that limits the regime is "absolutely null" (Law 27.742 art. 165).
Provinces, the CABA and municipalities are invited to adhere (art. 224). Those that adhere may not impose new local taxes on a VPU (the project vehicle), other than fees for services actually rendered that do not exceed the specific cost of the service. A "new" tax includes any change after 31 December 2023 to the taxable event, base, rate, deductions or exemptions that increases the burden (art. 225).
Transactions between a VPU and its members may not be taxed by any local tax (art. 188(b)).
Coparticipación explains why adhesion is a negotiation: the province gives up future gross income and stamp tax increases on the project while its general revenue depends on national transfers it does not control. See the RIGI page (unconfirmed).

Step by step

A. Assess the fiscal position of a province before you invest or lend

Download the province's budget execution from the Ministry of Economy (Ejecuciones presupuestarias, serie anual 24 jurisdicciones). Compute own taxes, national resources, royalties and transfers as shares of total revenue (Example 2 shows how). Time: one hour. Cost: free.
Check daily national transfers in the RON files (Recursos Tributarios de Origen Nacional, montos diarios), one sheet per province, in ARS million: coparticipación net of Law 26.075, education fund, special regimes, and Consenso compensations. A sharp fall in a month is a liquidity signal.
Check the provincial tax mix in the TOP files: how much depends on gross income tax and stamps. A province with high dependence on transfers and low own revenue has a stronger incentive to raise gross income tax rates, broaden withholding regimes or create municipal fees.
Search Infoleg for advances (anticipo financiero) to that province in the current year (verVinculos list of Law 23.548). An advance means part of next months' coparticipación will be retained.
Check debt authorisations under Law 25.917 art. 25 and the province's adhesion to the Fiscal Responsibility Regime.
Check adhesion to the RIGI (Law 27.742 art. 224) and to the Consenso Fiscal 2021 (Law 27.687) by provincial law (unconfirmed).

Cost to do it: no official fees; internal or adviser time of about 1 to 3 days for a first review. No capital requirement.

B. Challenge a provincial or municipal levy that duplicates a national tax

Identify the levy and the national tax it overlaps (for example a municipal "fee" calculated on turnover with no real service, or a local tax on a matter already taxed by VAT or excise). Law 23.548 art. 9(b) bans analogous local taxes but allows gross income, stamps, real estate and vehicle taxes and fees for services actually rendered.
Choose the route. (a) A complaint (denuncia) to the Federal Tax Commission under art. 11(d); (b) a refund claim before the local tax authority, which the law allows without going first to the Commission (art. 14), followed by local courts; (c) court action, ultimately before the Supreme Court. Routes can be combined (unconfirmed).
File with the CFI. Under the ordinance in force since 18 August 2026 the complaint is written and must contain the complainant's name and domicile, the precise identification of the tax and norms challenged, the reasons, and all evidence offered (CFI Ordinance art. 11), with the norms creating the tax attached digitally (art. 12). Taxpayers and recognised associations may file without a lawyer (art. 5), must give a physical domicile in the Capital Federal and an electronic domicile (art. 9), and filings are made through the CFI's electronic desk (art. 10).
Understand your role. Since 18 August 2026 taxpayers act as complainants, not parties. The parties are the Nation, the provinces, the CABA, municipalities and the agencies that issued the tax (art. 4). This change was approved by 18 jurisdictions with the Nation voting against (Resolution 287/2026, recitals). In practice you cannot appeal on your own as a party within the CFI; you are notified of the final decisions (art. 7) (unconfirmed).
Timeline. Answer by the issuing jurisdiction within 30 working days (art. 13); then legal and economic opinions; Executive Committee decision within 60 working days, extendable once (art. 19); review by the Plenary (arts. 22 and 23); extraordinary appeal to the Supreme Court within 10 days, without suspensive effect (arts. 25 and 26; Law 23.548 art. 12). Realistic total: many months to years (unconfirmed).
Keep paying or secure the debt while the complaint runs; a CFI complaint does not suspend the local tax (unconfirmed).

Cost to do it: the CFI decisions impose no costs or fees (CFI Ordinance art. 20) and no filing fee appears in the ordinance; lawyer not required for a complaint. Adviser fees and time are the real cost (unconfirmed). Months: at least 6 to 12 on the CFI's own deadlines, more with review and appeal.

C. Due diligence on a provincial bond or a payment risk

Read the indenture for the assignment of coparticipación and its ranking against other assignments (the Nation's retentions for advances rank by their own terms).
Check the Law 25.917 art. 25 authorisation and, for peso indexed bonds, the Budget Law exception (Law 27.798 art. 62).
Check advances and retentions in force (section 6) and the RON series for the province.
Check litigation between the province and the Nation (SAIJ search; Chubut 2024 shows that courts can order retentions to stop).

D. RIGI project in a province

Confirm the provincial (and municipal) adhesion law to the RIGI under art. 224 and its date.
Freeze the local tax baseline at 31 December 2023 (art. 225): list every provincial and municipal tax, rate and exemption in force at that date.
Monitor later changes and challenge any increase as a "new local tax" (arts. 165 and 225).

Costs and timelines

Table 1. Primary distribution: statute versus practice

Recipient	Law 23.548 art. 3	As applied (MECON scheme 2021 to present)	Note
National Treasury	42.34%	40.24%	CABA 1.40% and Tierra del Fuego 0.70% paid from the Nation's share (art. 8)
Provinces (22 in art. 4)	54.66%	57.36% including Tierra del Fuego and the 2% fund
Recovery fund (Buenos Aires 1.5701%, Chubut, Neuquén, Santa Cruz 0.1433% each)	2%	included in 57.36%
Tierra del Fuego	(art. 8)	0.70%	Decree 702/1999
CABA	(art. 8)	1.40%	Decree 705/2003; CSJN interim order says 2.95%
ATN fund	1%	1%	Discretionary, art. 5

Table 2. Secondary distribution among provinces (Law 23.548 art. 4)

Province	Share of the 54.66%	Effective share of the whole pool	Plus recovery fund (art. 3(c))
Buenos Aires	19.93%	10.894%	1.5701%
Catamarca	2.86%	1.563%
Córdoba	9.22%	5.040%
Corrientes	3.86%	2.110%
Chaco	5.18%	2.831%
Chubut	1.38%	0.754%	0.1433%
Entre Ríos	5.07%	2.771%
Formosa	3.78%	2.066%
Jujuy	2.95%	1.612%
La Pampa	1.95%	1.066%
La Rioja	2.15%	1.175%
Mendoza	4.33%	2.367%
Misiones	3.43%	1.875%
Neuquén	1.54%	0.842%	0.1433%
Río Negro	2.62%	1.432%
Salta	3.98%	2.175%
San Juan	3.51%	1.919%
San Luis	2.37%	1.295%
Santa Cruz	1.38%	0.754%	0.1433%
Santa Fe	9.28%	5.072%
Santiago del Estero	4.29%	2.345%
Tucumán	4.94%	2.700%
Total	100%	54.66%	2%

The third column is the art. 4 share multiplied by 54.66% (our calculation).

Table 3. Provincial own tax revenue by tax, 2025 (ARS million)

Jurisdiction	Gross income	Real estate	Stamps	Vehicles	Total own tax	Gross income share
Buenos Aires	10,624,324	873,918	1,468,316	755,351	14,036,639	75.7%
CABA	7,828,356	825,863	814,729	458,307	10,033,454	78.0%
Córdoba	2,503,107	200,870	372,209	117,251	3,193,987	78.4%
Santa Fe	2,465,333	151,901	249,542	5,861	2,881,400	85.6%
Neuquén	1,587,736	36,498	117,063	0	1,741,298	91.2%
Mendoza	1,107,923	52,973	129,226	96,965	1,388,558	79.8%
Formosa	142,784	819	19,746	0	163,666	87.2%
All 24 (La Pampa missing)	32,905,777	2,392,216	3,963,647	1,723,213	41,711,426	78.9%

Source: DNAP, Recursos tributarios provinciales, acumulado al IV trimestre 2025 (updated 12 June 2026). Total own tax revenue of ARS 41,711,426 million is US$ 26.7 billion.

Table 4. Deadlines in the coparticipación system

Step	Deadline	Source
Banco Nación transfer of shares	Daily, automatic	Law 23.548 art. 6
Province to municipalities	Automatic, every fortnight	Law 23.548 art. 9(g)
Suspension of a local tax declared in conflict	10 calendar days from notice	Law 23.548 art. 9(e)
Review request against a CFI decision	60 calendar days	Law 23.548 art. 12
Report of compliance with a CFI decision	90 days (60 after review)	Law 23.548 art. 13
Check of the 34% floor / payment of shortfall	15 Feb / 30 Apr of following year	Law 23.548 art. 20
ATN report to provinces	Quarterly	Law 23.548 art. 5
CFI procedure: answer to a complaint	30 administrative working days	CFI Ordinance art. 13 (Res. 287/2026)
CFI Executive Committee decision after opinions	60 working days, extendable once	CFI Ordinance art. 19
Review by the Plenary	Filed within 60 days; decided within 60 days of the opinions, extendable once	CFI Ordinance arts. 22 and 23
Extraordinary appeal to the CSJN	10 days from notice; no suspensive effect	CFI Ordinance arts. 25 and 26
Repayment of 2026 cash advances	Within fiscal year 2026	Decrees 219/2026, 474/2026, 584/2026

CFI Ordinance terms are counted in administrative working days (art. 6).

Table 5. Timeline of norms with Boletín Oficial dates

BO date	Norm	Effect
26 Jan 1988	Law 23.548	Transitional coparticipation regime from 1 Jan 1988
29 Nov 1990	Decree 2456/1990	Tierra del Fuego 0.388%
20 Apr 1992	Decree 559/1992	Collection costs deducted from the pool
22 Sep 1992	Law 24.130	Ratifies 12 Aug 1992 pact: 15% retention for pensions
25 Jan 1994	Decree 14/1994	Ratifies 12 Aug 1993 Federal Pact
10 Jan 1995	Law 24.430	Official text of the Constitution as reformed in 1994 (art. 75(2), Sixth transitional clause)
27 Sep 1996	Law 24.699	Extends the 1993 Federal Pact
14 Dec 1998	Law 25.049	Amends Law 23.548 art. 10 (CFI seat)
7 Jul 1999	Decree 702/1999	Tierra del Fuego 0.70%
30 Apr 2002	Decree 692/2002	CABA automatic daily transfers
6 May 2002	Law 25.570	2002 Nation provinces agreement
27 Mar 2003	Decree 705/2003	CABA 1.40%
25 Aug 2004	Law 25.917	Fiscal Responsibility Regime
12 Jan 2006	Law 26.075	Education financing earmark (art. 7)
1 Dec 2015	DNU 2635/2015	End of 15% retention (repealed by DNU 73/2016, BO 13 Jan 2016)
19 Jan 2016	Decree 194/2016	CABA 3.75%
22 Jul 2016	Law 27.260	Ratifies 2016 agreements phasing out the 15%
2 Jan 2018	Law 27.429	Consenso Fiscal 2017
2 Jan 2018	Law 27.428	New Law 25.917 art. 25 (debt authorisation)
3 Apr 2018	Decree 257/2018	CABA 3.50%
10 Sep 2020	Decree 735/2020	CABA 2.32%; fund for Buenos Aires province
28 Dec 2020	Law 27.606	Security transfer approved; CABA back to 1.40% plus security transfer
4 Oct 2022	Law 27.687	Consenso Fiscal 2021
21 Dec 2022 (ruling)	CSJN, CSJ 1865/2020	Interim order: CABA 2.95%
27 Dec 2022	Decision 1282/2022	Payment of the difference in TX31 bonds
26 Feb 2024	Decree 192/2024	Repeals the Buenos Aires province fund of Decree 735/2020
8 Jul 2024	Law 27.742	RIGI, arts. 224 and 225 on local adhesion
17 Mar 2025	Decree 190/2025	Advance to Chaco
12 Sep 2025	Decree 652/2025	Veto of the ATN bill 27.794
29 Dec 2025	Decree 922/2025	Advance to Entre Ríos
2 Jan 2026	Law 27.798	2026 Budget: education earmark (art. 13), 2002 agreement payments (art. 14), provincial peso bonds (art. 62)
19 Mar to 13 Jul 2026	Decrees 161, 219, 474 and 584 of 2026	Advances up to ARS 400,000 million per province at 15%
25 Aug 2026	CFI Resolution 287/2026	New CFI procedural ordinance from 18 Aug 2026

Worked examples

Example 1. Following ARS 100 of national VAT down to a province

Facts. A company in Mendoza pays ARS 100 of VAT to ARCA. Where does it go? We use VAT Law art. 52, Law 23.548 arts. 3, 4 and 8, the Ministry's official scheme, and September 2026 daily transfer data. We also scale it to ARS 1,000,000,000 (US$ 639,427).

Step 1. Tax agency deduction (1.9%). ARS 100 × 1.9% = ARS 1.90 to ARCA's budget; ARS 98.10 remains (MECON scheme note 1).

Step 2. VAT Law art. 52. 11% of ARS 98.10 = ARS 10.791 to social security, of which ARS 10.111 national (93.7%) and ARS 0.680 to provincial and municipal pension funds (6.3%) per the scheme (unconfirmed). 89% of ARS 98.10 = ARS 87.309 enters the shared pool.

Step 3. Primary distribution (as applied).

Recipient	% of pool	ARS per 100 of VAT	ARS per 1 bn of VAT	US$ per 1 bn of VAT
ATN fund	1.00	0.873	8,730,900	5,583
National Treasury	40.24	35.133	351,331,000	224,650
CABA (at 1.40%)	1.40	1.222	12,223,000	7,816
Provinces incl. Tierra del Fuego	57.36	50.080	500,804,000	320,228
Total pool	100	87.309	873,090,000	558,277

Within the provinces' ARS 50.080: ARS 47.723 is the art. 3(b) pool (54.66%), ARS 1.746 the recovery fund (2%) and ARS 0.611 Tierra del Fuego (0.70%).

Step 4. Secondary distribution (art. 4).

Province	Calculation	ARS per 100 of VAT	ARS per 1 bn	US$ per 1 bn
Mendoza	47.723 × 4.33%	2.066	20,664,000	13,213
Córdoba	47.723 × 9.22%	4.400	44,001,000	28,135
Buenos Aires	47.723 × 19.93% + 87.309 × 1.5701%	10.882	108,821,000	69,583
La Rioja	47.723 × 2.15%	1.026	10,260,000	6,561
Chubut	47.723 × 1.38% + 87.309 × 0.1433%	0.784	7,837,000	5,011

Step 5. Education earmark. Part of each province's share is earmarked for education (Law 26.075 art. 7; Law 27.798 art. 13). The amount is set annually, so the percentage varies. In September 2026 Córdoba's education column was 13.08% of its gross coparticipación (ARS 72,307 million of ARS 552,720 million, DNAP RON). Applied to Córdoba's ARS 4.400, about ARS 0.576 is earmarked and ARS 3.825 is free.

Step 6. Municipalities. Each province must pass part of its share to its municipalities by its own law with automatic fortnightly remittance (Law 23.548 art. 9(g)). The percentages are provincial law (unconfirmed).

Result. Of ARS 100 of VAT paid in Mendoza, about ARS 2.07 reaches the Mendoza provincial treasury through coparticipación (before its education earmark and municipal sharing), ARS 35.13 stays with the National Treasury, ARS 10.11 finances national pensions and ARS 1.90 funds ARCA. Where the VAT is paid does not matter: the share is the same whether the company is in Mendoza or elsewhere, because art. 4 uses fixed percentages, not origin.

If the CABA received 2.95%. The City's share per ARS 100 would be ARS 2.576 instead of ARS 1.222, and the Nation's would fall to ARS 33.780. Provincial shares do not change (CSJN, 21 December 2022, recital 10).

Cost to do it: none for the taxpayer. The example explains why a province receives only about 2 pesos of every 100 of national VAT and therefore relies on gross income tax.

Example 2. Own revenue versus transfers by province, 2025

Facts. You are choosing between provinces for a plant and want to know which ones depend most on national money. Source: DNAP provisional budget execution, non financial public administration, cumulative to Q4 2025, column 2025, ARS million. Shares are of total revenue (current plus capital). Columns do not add to 100% because social security contributions, non tax revenue and other items are not shown. La Pampa did not report 2025 data.

Jurisdiction	Own taxes (ARS m)	Own taxes (US$ m)	National tax resources (ARS m)	Royalties (ARS m)	Total revenue (ARS m)	Own taxes %	Own taxes + royalties %	National resources %	National ÷ own
CABA	10,033,454	6,416	1,310,198	0	13,546,590	74.1	74.1	9.7	0.13
Buenos Aires	14,036,638	8,975	13,691,854	0	34,522,845	40.7	40.7	39.7	0.98
Neuquén	1,741,298	1,113	1,018,358	2,303,729	7,402,260	23.5	54.6	13.8	0.58
Chubut	593,238	379	930,534	455,798	2,743,747	21.6	38.2	33.9	1.57
Santa Cruz	376,020	240	907,861	403,983	2,331,646	16.1	33.5	38.9	2.41
Mendoza	1,388,558	888	2,377,211	172,963	4,503,702	30.8	34.7	52.8	1.71
Córdoba	3,193,987	2,042	5,021,540	0	11,861,922	26.9	26.9	42.3	1.57
Santa Fe	2,881,400	1,842	5,155,859	0	10,728,945	26.9	26.9	48.1	1.79
Tucumán	1,124,642	719	2,757,996	0	4,093,098	27.5	27.5	67.4	2.45
Salta	765,695	490	2,283,772	42,094	3,294,558	23.2	24.5	69.3	2.98
San Juan	323,058	207	1,902,762	61,699	2,558,900	12.6	15.0	74.4	5.89
Catamarca	225,017	144	1,537,681	8,942	1,936,240	11.6	12.1	79.4	6.83
Chaco	427,061	273	2,917,372	0	4,174,364	10.2	10.2	69.9	6.83
La Rioja	154,865	99	1,163,068	0	1,364,783	11.3	11.3	85.2	7.51
Santiago del Estero	270,915	173	2,356,061	0	3,617,168	7.5	7.5	65.1	8.70
Formosa	163,666	105	2,065,123	2,149	2,780,994	5.9	6.0	74.3	12.62
All 24 (consolidated)	41,711,426	26,671	59,388,353	3,728,880	131,129,866	31.8	34.7	45.3	1.42

Step 1. Compute dependence. Divide national resources by own taxes. For Formosa: 2,065,123 ÷ 163,666 = 12.62, so it receives about 12.6 pesos of national tax money for each peso it collects. For the CABA: 1,310,198 ÷ 10,033,454 = 0.13.

Step 2. Add royalties for resource provinces. Neuquén's own taxes are 23.5% of revenue, but with royalties (ARS 2,303,729 million, art. 124 resources) its own resources reach 54.6%, and national resources are only 13.8%.

Step 3. Read it as an investor. * Low dependence (CABA, Buenos Aires province, Neuquén): the budget rides on local taxes or royalties, so local tax policy (gross income tax rates, withholding regimes, stamp tax) is the main fiscal lever and the main risk for a business; national cuts matter less. * High dependence (Formosa, Santiago del Estero, La Rioja, Catamarca, Chaco): the province's ability to pay suppliers, salaries and bonds tracks national tax collection and national discretionary decisions. A fall in VAT and income tax collection or a retention for an advance hits it directly. Several of them (Catamarca, Chaco, La Rioja) are among the twelve provinces eligible for advances under Decree 219/2026. * Middle (Córdoba, Santa Fe, Mendoza): both effects matter.

Step 4. Caveats. Own revenue in US$: Buenos Aires province ARS 14,036,638 million = US$ 8.98 billion; Formosa ARS 163,666 million = US$ 104.7 million. Provincial data are provisional and the Ministry warns they may differ from provincial publications.

Cost to do it: free data; about one day of analyst time.

Example 3. A 2026 cash advance and the retention of coparticipación

Facts. A province listed in Decree 219/2026 draws the maximum ARS 400,000,000,000 (US$ 255.8 million) at the start of a quarter. Interest is at a 15% fixed nominal annual rate (art. 2) and the advance must be repaid within fiscal year 2026 by retention of its coparticipación (arts. 1, 2 and 4).

Step 1. Interest (simple interest assumption). 400,000,000,000 × 15% × months/12:

Repaid after	Interest ARS	Interest US$
3 months	15,000,000,000	9,591,406
6 months	30,000,000,000	19,182,812
9 months	45,000,000,000	28,774,218

(unconfirmed)

Step 2. Compare with inflation. Twelve month inflation in September 2026 was 33.4% (BCRA series 28), so a 15% nominal rate was negative in real terms if inflation stays at that pace: cheap money for the province.

Step 3. What it means for creditors and suppliers. When repayment starts, the retention reduces the province's daily RON receipts. For a province whose national resources are, say, 70% of revenue (Example 2), the retention of ARS 400,000 million plus interest over a few months is a large share of its cash flow. A supplier or bondholder should check whether its own payment depends on the same flow.

Cost to do it: no fee for the province beyond interest; for an investor, reading the decree and the RON series takes an hour.

Example 4. The CABA gap between 1.40% and 2.95%, September 2026

Facts. DNAP daily data for September 2026 show, in ARS million: CABA coparticipación net of Law 26.075 = 99,290.8; education column = 54,255.8; gross = 153,546.6. All 24 jurisdictions gross = 6,457,628.4, so the 23 provinces = 6,304,081.8.

Step 1. Which coefficient do the data reflect? 153,546.6 ÷ 6,304,081.8 = 2.436%. The ratio 1.40 ÷ 57.36 = 2.441%, while 2.95 ÷ 57.36 = 5.143%. The automatic transfer therefore matches 1.40%.

Step 2. Size of the gap. At 2.95% the City's gross share would be 153,546.6 × 2.95 ÷ 1.40 = ARS 323,544.5 million. The monthly gap is ARS 169,998 million, about US$ 108.7 million, for September 2026 alone.

Step 3. Reading it. Either the difference is being paid outside the automatic RON flow (as with the TX31 bonds of Decision 1282/2022) or it is not being paid in full. The sources do not say which (unconfirmed). For a CABA bond investor or supplier, this is a contested receivable of the City against the Nation.

Cost to do it: none; arithmetic on public data.

Practical traps

Reading the statute and stopping there. Law 23.548 says 42.34% for the Nation; the Ministry applies 40.24% after the CABA and Tierra del Fuego, deducts 1.9% for ARCA first, and VAT enters only at 89%. Use the official scheme and the RON data, not the 1988 text alone.
Assuming the CABA is in art. 4. It is not. The City is paid from the Nation's share by decree (art. 8), which is why its percentage has moved five times since 2003 and is in court.
Assuming the Supreme Court's 2.95% is what the City gets. The 2022 order is interim, and the 2026 automatic flow matches 1.40% (Example 4).
Treating "fees" as safe. Municipal and provincial fees are outside the art. 9(b) ban only if they pay for a service actually rendered; fees on turnover without a matching service are frequently challenged. See Municipal fees.
Expecting a CFI complaint to protect you. Since 18 August 2026 the taxpayer is only a complainant (CFI Ordinance art. 4), the procedure does not suspend the tax, and appeals have no suspensive effect (Law 23.548 art. 12).
Relying on fiscal pact caps as if they were provincial law. Consensos bind provinces only once ratified by the provincial legislature and implemented in the tax code; Consenso 2021 replaced the earlier commitments (clause 16).
Ignoring retentions. Advances (2025 and 2026 decrees), development fund loans (Chubut 2024) and debt agreements (Law 25.570 art. 8) are repaid by retaining coparticipación before it reaches the province. Your payment from a province may depend on what is left.
Assuming the ATN is formula based. It is discretionary (art. 5) and the 2025 attempt to make it automatic was vetoed (Decree 652/2025).
Assuming the education money is free. Part of each province's share is earmarked under Law 26.075 art. 7 every year (2026: Law 27.798 art. 13).
Mixing nominal and real figures. With 117.8% inflation in 2024 and 31.5% in 2025 (December to December), nominal growth in transfers can hide real falls (section 6).
Forgetting municipalities. RIGI adhesion by a province does not bind its municipalities unless they adhere too (art. 224 invites provinces, the CABA and municipalities separately).

Recent changes

26 Feb 2024. Decree 192/2024 repealed the fund for Buenos Aires province created with the CABA's reduced share (Decree 735/2020 art. 4).
27 Feb 2024. Federal court orders the Nation to stop retaining Chubut's coparticipación for development fund loans during that fiscal year (SAIJ summaries).
8 Jul 2024. Law 27.742 creates the RIGI, inviting provincial and municipal adhesion and freezing local taxes at 31 Dec 2023 for adhering jurisdictions (arts. 224 and 225).
2024 and 2025. Current and capital transfers to provinces fell sharply in real terms in 2024 and partly recovered in 2025 (DNAP APNF).
17 Mar 2025. First of a series of cash advances against coparticipación (Chaco, Decree 190/2025, at TAMAR).
12 Sep 2025. Veto in full of bill 27.794 that would have distributed the ATN fund automatically (Decree 652/2025).
2 Jan 2026. Budget Law 27.798: education earmark extended for 2026 (art. 13), payments under the 2002 agreement (art. 14), provincial peso bond exception (art. 62).
March to July 2026. Advances of up to ARS 400,000 million per province to 16 provinces at a 15% fixed rate (Decrees 161, 219, 474 and 584 of 2026).
18 Aug 2026. New CFI procedural ordinance: taxpayers become complainants, not parties; electronic domiciles and filings (Res. 287/2026, BO 25 Aug 2026).

Pending changes

The new coparticipation ley convenio required since 1996 (Constitution art. 75(2) and Sixth transitional clause). Not enacted. The national executive refers to a commitment in the "Pacto de Mayo" to rediscuss the regime (Decree 652/2025, recitals) (unconfirmed).
The federal fiscal body required by art. 75(2) has not been created by law (unconfirmed).
CABA case CSJ 1865/2020: final judgment pending; payment of the 2.95% interim share unclear (unconfirmed).
ATN bill 27.794: veto override not recorded in Infoleg (unconfirmed).
Earmarks: prorogued "until 31 December 2027" for national coparticipable taxes by Law 27.702 art. 2 (Infoleg note in the VAT Law). Their renewal or expiry will change the pool (unconfirmed).
Consenso Fiscal 2021 follow up: no later pact in the sources (unconfirmed).
RIGI adhesions by provinces and municipalities (unconfirmed).

FAQ

1. What is coparticipación in one sentence? It is the system by which the Nation shares most national taxes with the provinces and the CABA, under Law 23.548 of 1988: about 40% stays with the National Treasury and about 57% goes to the provinces by fixed percentages, with small shares for the CABA and a discretionary 1% fund.

2. Why is a 1988 "transitional" law still in force? Because art. 15 extends it automatically until a replacement exists, and the replacement must be a ley convenio passed by an absolute majority of each chamber and approved by every province (Constitution art. 75(2)). The 1996 deadline of the Sixth transitional clause passed without agreement.

3. Does the province where I pay VAT get more of it? No. The secondary distribution uses fixed percentages (art. 4), not the place of collection. Mendoza gets about ARS 2.07 of each ARS 100 of VAT wherever it is paid (Example 1).

4. Which national taxes are not shared? Import and export duties (Law 23.548 art. 2(a)), and taxes with their own regimes or earmarks. The bank debit and credit tax goes 100% to national social security under the current scheme, and part of VAT and of other taxes goes to pensions before sharing.

5. How much of a province's money is its own? On average 31.8% of provincial revenue in 2025 came from own taxes and 45.3% from national tax resources, but it ranges from 74.1% own taxes in the CABA to 5.9% in Formosa (Example 2).

6. Why is gross income tax so high and so hard to escape? It is the provinces' main own tax (78.9% of own tax revenue in 2025), it is expressly allowed by Law 23.548 art. 9(b), and provinces with high spending and fixed transfer shares have few other options. The fiscal pacts set caps, but each province must implement them. See the gross income tax page.

7. Can I challenge a local tax as contrary to coparticipación? Yes. You may file a complaint with the Federal Tax Commission (art. 11(d)), claim a refund directly from the local tax authority (art. 14) or go to court. Since August 2026 a taxpayer is a complainant, not a party, before the Commission (Res. 287/2026).

8. What did the Supreme Court decide on the CABA? On 21 December 2022, as an interim measure, it ordered the Nation to pay the City 2.95% of the shared pool and not to apply Law 27.606, because functions transferred by agreement cannot be defunded unilaterally. There is no final judgment in the sources. The Nation first paid the difference in TX31 bonds (Decision 1282/2022).

9. What are ATN and can a province count on them? The 1% Fondo de Aportes del Tesoro Nacional, distributed at the discretion of the national executive for emergencies (arts. 3(d) and 5). They are not predictable; a 2025 bill to distribute them automatically was vetoed.

10. Do provincial bonds benefit from coparticipación? Often the province assigns its coparticipación as security, and the Nation itself retains coparticipación to recover advances and loans. That gives bondholders a strong collection mechanism but also means competing claims on the same flow. Check the indenture and the Law 25.917 art. 25 authorisation.

11. If a province adheres to the RIGI, are my provincial taxes frozen? Only for a RIGI project vehicle, and only against "new" local taxes compared with 31 December 2023; fees for services actually rendered at cost are still allowed (Law 27.742 art. 225). Municipalities must adhere separately.

12. Does the CABA case affect what my province gets? No. The Court said the City's share comes only from the Nation's share, so provinces are not affected (CSJ 1865/2020, recital 10).

Published 27 Oct 2026 from our research draft. Points marked (unconfirmed) have not yet been checked line by line against the official text; rely on the primary sources linked below before acting, and expect this page to change as we verify it.