Municipal fees in Argentina: tasa de seguridad e higiene and other local charges

Q: Is the TISH a tax or a fee?

Legally a fee ( tasa ): it must pay for a concrete, effective and individualised service such as inspection of your premises ( Laboratorios Raffo , Fallos 332:1503; Law 23.548 art. 9(b)). In practice it is usually calculated on gross income, which is why it is often litigated as a disguised tax.

Q: Can the fee be much higher than the cost of the inspections?

No, according to the CSJN. In Mutual Pergamino (2026) the Court said total collections should not exceed "for example up to double" the cost of the service, and no taxpayer may bear an exorbitant share. Proving it requires the municipality's budget and collection data.

Last verified: 27 Oct 2026 · Status: Changing

Argentina has three levels of taxing government: the Nation, the 23 provinces plus the Autonomous City of Buenos Aires (CABA), and roughly two thousand municipalities and communes (unconfirmed). Municipalities do not have their own national framework law. Each province regulates its municipal regime under its own constitution and organic municipal law, and the Federal Constitution requires provinces to ensure municipal autonomy "in the institutional, political, administrative, economic and financial order" (Constitution art. 123, with art. 5).

For a business, the most important municipal charge is the fee on commercial, industrial and service premises. Most municipalities in the Province of Buenos Aires (PBA) call it the Tasa por Inspección de Seguridad e Higiene (TISH). Córdoba City calls it the Contribución que incide sobre la actividad comercial, industrial y de servicios (Código Tributario Municipal art. 231, Ordinance 10.363, as quoted by the CSJN in Banco de Galicia, 10 September 2026). Rosario calls its equivalent the Derecho de Registro e Inspección (unconfirmed). Whatever the name, the legal theory is the same: it is a fee (tasa) that pays for inspection of safety, health and hygiene conditions in the places where activity is carried out, but in practice it is usually measured as a percentage of gross income, which makes it look and feel like a second, municipal turnover tax.

Five points define the regime:

A fee needs a real service. Under long standing Supreme Court case law, a tasa is valid only if it corresponds to a concrete, effective and individualised service relating to the taxpayer's own property or acts (CSJN, Laboratorios Raffo, Fallos 332:1503, as restated in Banco de Galicia c/ Municipalidad de Córdoba, 10 September 2026, cons. 3). Law 23.548 art. 9(b) repeats the idea from the federal side: provinces and their municipalities may not levy local taxes analogous to shared national taxes, but the ban does not reach tasas retributivas de servicios efectivamente prestados.
The municipality carries the burden of proof when the taxpayer denies that any service was provided (CSJN Quilpe, Fallos 335:1987; Gasnor, Fallos 344:2728; Mutual Pergamino, 10 September 2026, cons. 8). In 2026 the Court added that inspections must be periodic, and that a single inspection made after the lawsuit was filed does not prove the service for decades of fees (Mutual Pergamino, cons. 8 to 11).
The amount must be proportionate to the cost of the service. Using gross income as a measure of capacity is allowed, but not if the result is unreasonable or disconnected from the cost of the service (CSJN Esso Petrolera Argentina c/ Municipalidad de Quilmes, Fallos 344:2123, as summarised in Mutual Pergamino, cons. 14). In Mutual Pergamino the Court said total collections could never reasonably exceed "an important part, for example up to double" the direct and indirect cost of the service (cons. 15).
Multi jurisdiction businesses pay only on the provincial share of their income. Under CM art. 35, municipalities may tax CM activities only on the part of gross income attributed to their province, split among municipalities using CM rules. Where local law requires premises, the municipalities where the taxpayer holds a licence may together tax 100% of the provincial share.
The national government is pushing back. Since September 2024 consumer invoices may not include charges unrelated to the good or service sold, which blocks municipalities from collecting fees through utility and other bills (Resolution of the Secretaría de Industria y Comercio, "Res. SIC", 267/2024, art. 1, BO 11 September 2024). Fuel stations must display a notice where municipalities levy fees on fuel prices (Res. Secretaría de Energía, "Res. SE", 259/2024, art. 3, BO 17 September 2024). In January 2025 the Ministry of Economy asked the provinces to make their municipalities repeal disproportionate fees, and in December 2025 it published a municipal tax transparency portal (argentina.gob.ar news, 8 January 2025 and 17 December 2025).

The CABA is a special case. It is not a province with municipalities but an autonomous city (Constitution art. 129), and it levies gross income tax itself. some secondary summaries for this page says the City has no TISH because gross income tax takes its place; no CABA source was available to confirm how the City's Código Fiscal treats this (unconfirmed).

Who should read this page. Foreign investors choosing where to put a plant, warehouse or store; retailers and distributors with branches in several cities; service companies that sell into municipalities where they have no premises; local SMEs facing a municipal assessment; and advisers preparing CM coefficients. Related pages: Gross income tax (provincial turnover tax and the CM), Stamp tax (provincial tax on instruments) and IGJ vs provincial registries (where to register the company, which does not decide where municipal fees are owed).

Cost to do it. There is no single national figure. Registering a store or plant for the municipal fee requires a municipal operating licence (habilitación) in each municipality, with a one off fee and processing time set by each ordinance (unconfirmed). The recurring cost is the fee itself, typically a percentage of the gross income attributed to that municipality plus fixed minimums. Challenging an assessment is slow: the Banco de Galicia determination dates from 2008 and the Supreme Court ruled in September 2026; Western Union c/ Municipalidad de Merlo (file FSM 2350/2006) was decided in April 2025; the Pergamino mutual sued in 2016 and won in the Supreme Court in September 2026. Plan for ten years or more if a case goes to the Supreme Court, and budget professional fees accordingly (unconfirmed).

COMPARISON: to be sourced by editor

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

A. Constitutional framework: who may charge what

Municipal autonomy. Each province must ensure the municipal regime (art. 5) and "municipal autonomy, regulating its scope and content in the institutional, political, administrative, economic and financial order" (art. 123). Municipal taxing power is therefore real but derived: its scope comes from the provincial constitution and organic municipal law, and it must respect federal limits.
Establishments of national utility. Provincial and municipal authorities keep police and taxing powers over establishments of national utility (ports, airports, the Mercado Central and similar) as long as they do not interfere with their specific purposes (Constitution art. 75(30), cited by the Federal Court of Appeals in the Diarco case summarised by the CSJN on 12 March 2025).
CABA. The City has an autonomous regime with its own legislative and judicial powers (art. 129). It has no municipalities in the provincial sense (unconfirmed).
What a tasa is. The CSJN describes a tasa as a tax category derived from the State's power to tax, consisting of a state activity that concerns the taxpayer. Once the State organises the service and makes it available, the taxpayer must pay even if the taxpayer does not use it or has no interest in it, because it serves the general interest (Western Union c/ Municipalidad de Merlo, 10 April 2025, concurring vote cons. 7, citing Fallos 251:50, 312:1575, 323:3770, 326:4251, 332:1503 and 344:2123).
Three conditions for a valid fee. A municipal fee requires: (a) a clear and precise definition of the taxable event and identification of the services offered; (b) organisation of the service and making it available to the taxpayer, otherwise the charge has no cause and violates property rights; and (c) adequate and precise quantification, weighing among other factors the global cost of the service and the taxpayer's capacity to pay (Banco de Galicia, 10 September 2026, concurring vote cons. 5; the same three conditions are attributed to Gasnor, Fallos 344:2728, in Mutual Pergamino, concurring vote cons. 2).

B. Federal limits: Law 23.548 art. 9(b)

Each province adhering to the federal tax sharing system undertakes, for itself and for its municipalities, not to apply local levies analogous to the shared national taxes. The undertaking covers "taxes, fees, contributions or other tributes, whatever their characteristics or name", but "does not reach fees for services actually rendered" (tasas retributivas de servicios efectivamente prestados) (Law 23.548 art. 9(b), first and second paragraphs). In Mutual Pergamino the CSJN said this wording reaffirms the requirement of an "effective" service and makes periodicity of the service an essential attribute of the fee, so that it does not become a disguised tax (cons. 11, citing Fallos 347:653).

The Ministry of Economy relied on the same article in its 8 January 2025 note to the 23 provinces. The note asked them to have municipalities repeal fees that overlap, totally or partly, with the taxable events or bases of shared national taxes, that bear no reasonable relation to the cost of the service, or that ignore CSJN case law, and to consider suspending non complying municipalities from their share of tax revenue (argentina.gob.ar news, 8 January 2025). A ministerial note is not a binding norm, and no implementing resolution was found (unconfirmed).

C. The Convenio Multilateral and municipalities (CM art. 35; RG CA 106/2004)

CM art. 35 has four sentences, and each one matters:

Municipalities, communes and similar local bodies of adhering jurisdictions may tax CM activities through "taxes, fees, inspection duties or any other tribute" that local laws allow on trade, industry or activities in their territory, only on the part of gross income attributable to the province under the CM.
That amount is distributed among municipalities using the CM rules, unless an interjurisdictional agreement replaces that distribution within the province.
Where local law allows the levy only if the taxpayer has premises, an establishment or an office where the taxed activity takes place, the municipalities where the taxpayer holds the corresponding licence (habilitación) may together tax 100% of the amount attributable to the province.
The article does not bind jurisdictions where it contradicts express constitutional provisions.

The Comisión Arbitral regulated art. 35 in RG CA 106/2004 and RG CA 113/2005 (updated text "Municipios"):

Art. 35 applies to all municipalities, communes and similar local bodies (art. 1).
The general regime or the special regimes of the CM apply, depending on the activity, to split the base among municipalities (art. 2).
The coefficient for each municipality is calculated by relating the income and expenses that actually belong to each municipality to the provincial total, under the general regime of CM art. 2 (or the special regimes where they apply); the resulting coefficient is then applied to the gross income attributable to the province. This does not apply where an interjurisdictional agreement exists (art. 6, sources RG CA 106/2004 art. 9 and RG CA 113/2005 art. 1).
Municipal disputes can go to the Comisión Arbitral as a caso concreto. The caso concreto is the first administrative act of the municipality that, once final, allows enforcement, provided the taxpayer files with the Comisión within the time limit local law gives for appeals before the municipality itself (art. 3, source RG CA 106/2004 art. 4). The Comisión informs the province, and the municipality must send the full audit file (art. 4). The taxpayer must attach the inspection file, the administrative act, the provincial gross income returns for the years audited and all supporting evidence (art. 5).

How far art. 35 actually limits a municipality is contested. In Banco de Galicia the Córdoba High Court held that including income that is exempt or not taxed for gross income purposes in the municipal base does not exceed the provincial share, and that Córdoba's Código Tributario Municipal art. 232 adopted the CM technical rules. The CSJN concurring vote declined to review that point because the CM and Law 23.548 are local public law that the Supreme Court does not interpret on extraordinary appeal (Banco de Galicia, concurring vote cons. 8, citing Papel Misionero, Fallos 332:1007). In practice, disputes about how much of the base belongs to which municipality are decided by the Comisión Arbitral and provincial courts, not by the CSJN, unless a constitutional question (the nature of the fee, proportionality) is raised.

The gross income tax page explains how the provincial coefficient is built: see Gross income tax, section D.

D. Provincial organic municipal laws

Each province sets the list of resources its municipalities may levy. The texts could not be downloaded for this page:

Province of Buenos Aires: Decree Law 6769/58, Ley Orgánica de las Municipalidades, amended among others by provincial Laws 14.515 (2013), 14.732 (2015), 14.872 (2016), 15.103 (2018) and 15.315 (2021) (titles listed in SAIJ). Its list of municipal fees, including the inspection fee, is commonly cited as art. 226 (unconfirmed). Municipalities pass an annual Ordenanza Fiscal (taxable events, taxpayers, procedure) and Ordenanza Impositiva or Tarifaria (rates and minimums) (unconfirmed). The Merlo TISH was created by Ordinance 1812/00 as amended by Ordinance 2187 (Western Union, concurring vote cons. 1). The Pergamino TISH is in arts. 85, 87, 88 and 94 of its Ordenanza Fiscal (Mutual Pergamino, concurring vote cons. 1). In Western Union the municipality also invoked art. 190 of the PBA Constitution.
Córdoba: the province's municipal regime law is commonly cited as Law 8102 (unconfirmed); SAIJ lists several provincial laws that change municipal boundaries "in accordance with Law 8102". Córdoba City has its own municipal charter (Carta Orgánica), and the Córdoba High Court relied on arts. 2, 43, 45 and 47 of that charter, arts. 180, 186, 188(1) and 189 of the Córdoba Constitution and art. 167 of the Código Tributario Municipal to hold that the City may levy taxes, not only fees (Córdoba High Court, Laboratorios Raffo, 1 October 2010, point 6). The CSJN rejected that recharacterisation in Syngenta (28 May 2013) and again in Banco de Galicia (2026).
Santa Fe: the organic law for cities is commonly cited as Law 2756 (unconfirmed); SAIJ lists Santa Fe laws declaring towns to be cities "under the regime of Law 2756". Rosario's fee rules are in its Código Tributario Municipal and Ordenanza General Impositiva (unconfirmed).
Mendoza: organic municipal law commonly cited as Law 1079 (unconfirmed); municipal tariff ordinances for Mendoza City (unconfirmed).

Practical consequence: before opening premises, ask the municipality (or a local adviser) for the current Ordenanza Fiscal and Tarifaria, and read the chapter on the commerce and industry fee in full: taxable event, base, rates by activity, minimum amounts per premises or per employee, filing frequency, and exemptions.

E. The commerce and industry fee in practice

From the cases in the source files, the typical structure is:

Feature	What the sources show	Source
Taxable event	Inspection services to preserve safety, health and hygiene in premises, establishments or offices where commercial and other activities take place	Merlo TISH, Western Union (2025), concurring vote cons. 1
Broad "catch all" version	Córdoba City: exercise of any commercial, industrial, service or other activity for consideration, and any act to promote, publicise, encourage or display it, "by virtue of the municipal services of control, health, hygiene, social assistance, development of the economy and any other not paid by a special tribute, but which tends to the well being of the population"	CTM art. 231 (Ord. 10.363), quoted in Banco de Galicia (2026), cons. 1 and concurring vote cons. 9
Base	Gross income of the taxpayer (Pergamino; Córdoba with CM technical rules in CTM art. 232)	Mutual Pergamino (2026), concurring vote cons. 1; Banco de Galicia, concurring vote cons. 2
Example amount	The Pergamino mutual said it had to pay ARS 8,523 per month in 2015, measured on its gross income	Mutual Pergamino, concurring vote cons. 1
Penalties	Córdoba CTM art. 101 allowed a fine of 50% to 200% of the omitted tax; 70% was applied to the bank (periods 2001 to 2005)	Banco de Galicia, concurring vote cons. 2 (unconfirmed)
Enforcement	Tax collection lawsuits (apremio) in provincial courts; La Matanza obtained a judgment for ARS 23,108,513.17 for TISH periods 12/2002 to 2004	Procuración opinion in Diarco (2025), point I

The CSJN has repeatedly struck down catch all definitions that describe the services "by default and residually" ("any other not paid by a special tribute"), calling them "an alibi to tax activities of taxpayers for whom no service or benefit is provided" (Gasnor, Fallos 344:2728, cons. 9, quoted in Banco de Galicia, cons. 5 and 6). Where the definition is that broad, the municipality, not the taxpayer, must prove that it organised and made the service available (Banco de Galicia, cons. 6; concurring vote cons. 9).

F. Supreme Court case law: the core doctrines

1. Concrete, effective and individualised service. "The collection of a fee must always correspond to the concrete, effective and individualised provision of a service relating to something no less individualised (property or act) of the taxpayer" (Procuración opinion adopted in Laboratorios Raffo, Fallos 332:1503, quoted in Banco de Galicia, cons. 3; earlier cases cited: Fallos 234:663, 236:22, 251:222, 259:413, 312:1575, 325:1370, 329:792). In Raffo the Court invalidated Córdoba City's contribution because the services it claimed to fund (building control, transport coordination, traffic, street naming and "organising the basic rules" for business) were not a concrete service to the taxpayer. The date of the Raffo judgment is commonly given as 23 June 2009 (unconfirmed). The Córdoba High Court complied on remand on 1 October 2010, annulled the assessment and ordered a refund, while openly disagreeing with the reasoning.

2. No relabelling as a tax. In Syngenta Agro c/ Municipalidad de Córdoba (28 May 2013) the CSJN overturned the Córdoba High Court, which had upheld the same contribution by recharacterising it as a municipal tax (Banco de Galicia, cons. 3).

3. Burden of proof on the municipality. If the taxpayer denies that the service was provided, the municipality must prove it, because it is in a better position to do so; requiring the taxpayer to prove a negative would frustrate the right (Quilpe, Fallos 335:1987, decided 9 October 2012 according to SAIJ, concerning a fee of the City of La Rioja; Gasnor, Fallos 344:2728, decided 7 October 2021 according to SAIJ, concerning La Banda; Mutual Pergamino, cons. 8).

4. Periodic service. A single inspection after the lawsuit was filed does not prove that a service was provided during the previous decades. "Nothing ensures the care of hygiene and safety more than the regular and effective inspection of taxpayers' premises", and periodicity is an essential attribute of the fee (Mutual Pergamino, 10 September 2026, cons. 10 and 11). This rejected the PBA Supreme Court view that fees need not be backed by inspections in each period because voluntary compliance is encouraged by the mere possibility of inspection.

5. Proportionality and the "up to double" benchmark. The Court treats the amount as valid only if two concurrent tests are met (Mutual Pergamino, cons. 15): * a general cap: total collections must be roughly limited by the global cost of the service; collections "could never reasonably exceed an important part, for example up to double" the direct and indirect cost of organising and providing the specific service, because anything above that funds other services or general government; failing this test alone invalidates the fee; * an individual test: capacity to pay may be used only to spread the cost among taxpayers; a fee that places an exorbitant burden on a particular taxpayer, unrelated to the cost of serving that taxpayer, is invalid even if the global cap is respected.

The Court rejected the PBA Supreme Court's view that only confiscatory fees can be challenged (cons. 16).

6. Gross income as a measure is allowed, within limits. "There are no constitutional objections to using the taxpayer's gross income as an indicator of capacity to pay and a factor for calculating the base" of a fee like the TISH, "as long as this does not lead to results that are unreasonable, disproportionate and disconnected from the direct and indirect services the municipality provides" (Esso Petrolera Argentina SRL y otro c/ Municipalidad de Quilmes, Fallos 344:2123, quoted in Mutual Pergamino, cons. 14). In Esso the Quilmes TISH base included income earned in other PBA municipalities where the company had no licensed premises. The Banco de Galicia concurring vote cites the same case as Fallos 344:2133; the two rulings give different page numbers (unconfirmed).

7. No double charge for the same premises. In Western Union c/ Municipalidad de Merlo (10 April 2025) the company had no premises of its own in Merlo and worked through agents (the postal service and two finance companies) inside their shops. The majority applied Municipalidad de Concordia c/ Nación AFJP (26 March 2009) and set aside the judgment that had ordered the company to pay. The concurring vote added that the municipality had not shown that the money transfer activity required an inspection service different in nature or intensity from the one already provided to, and paid for by, the shop owners; charging twice for checking the same safety and hygiene conditions of the same premises is unacceptable (cons. 8).

8. Do not use federal courts to block a final provincial judgment. In Autoservicio Mayorista Diarco c/ Municipalidad de La Matanza (12 March 2025) the taxpayer had lost its TISH challenge in the administrative and provincial courts and then obtained a federal injunction stopping enforcement of a final provincial apremio judgment, arguing that it operated inside the Mercado Central (an establishment of national utility). The CSJN overturned the injunction as a "generic jurisdictional immunity" that interfered with the provincial courts, and sent the case to the provincial administrative court in San Justo. In La Gran Dulce c/ Municipalidad de La Matanza (25 June 2026) a "leapfrog" appeal (recurso por salto de instancia) against a federal appeals court decision was declared inadmissible.

G. Fiscal pacts: commitments on municipal fees and what became of them

Pact	Commitment on municipal fees	What happened
Pacto Federal 1993 (signed 12 August 1993; ratified by Decree 14/1994, BO 25 January 1994), clause PRIMERO 2)	Provinces would "promote the repeal" of municipal fees that hit the same economic events as the provincial taxes being repealed, and of municipal fees in general that do not pay for a service actually rendered or exceed its cost. Clause PRIMERO 5) recommended that road and road maintenance fees not exceed 0.40% of 80% of the market value of suburban land (or land value without improvements) and match the cost of the service	The PBA Supreme Court, as summarised by the CSJN, treated this as a commitment "of means" that did not take away municipal powers (Mutual Pergamino, cons. 4). The CSJN did not rule on that point (cons. 17)
Consenso 2017 (Law 27.429, BO 2 January 2018), clause III(p), (q), (r)	(p) Adapt municipal fees so they match a concrete, effective and individualised service with amounts reasonably proportional to its cost; (q) create a public database per province of the fees in each municipality (taxable events, bases, taxpayers, rates and norms); (r) promote a single system for assessing and paying municipal fees per province and in the CABA	Not among the clauses suspended by Consenso 2019 and Consenso 2020 (the suspensions covered clause III(b), (c), (d), (h), (j), (k), (l), (m) and (s): Consenso 2020 clause II.A.1)
Consenso 2021 (Law 27.687, BO 4 October 2022), clause DECIMOSEXTA	Parties "leave without effect" all provincial tax commitments from the 2017, 2018, 2019 and 2020 pacts, keeping only those already fulfilled at signing (27 December 2021) and those expressly restated. Clause PRIMERA(a) and (b) only commit to information exchange (municipalities "invited") and to a federal simplification programme covering national, provincial and municipal rules	The 2017 municipal commitments survive only where a province had already fulfilled them (unconfirmed)

So the commonly cited pointer "Fiscal Pact 2017 and its suspension" needs a correction: the municipal commitments of Consenso 2017 were not suspended in 2019 or 2020. They were dropped by Consenso 2021 unless already fulfilled. The national government's 2025 public database is a federal initiative, not the provincial database promised in clause III(q).

H. National measures since 2024

Law 27.743, Title VII ("Régimen de Transparencia Fiscal al Consumidor"), BO 8 July 2024. Sellers to final consumers must show the final price and the net price without VAT and other national indirect taxes, and invoices must itemise VAT and other national indirect taxes (art. 99). The same article invites provinces and the CABA to make consumers aware of the incidence of gross income tax "and the respective municipal tributes" on prices. It is an invitation, not an obligation, for local taxes.

Res. SIC 267/2024 (BO 11 September 2024). The information on receipts issued by suppliers to consumers (Law 24.240 art. 3) "must refer only and exclusively to the good or service specifically contracted by the consumer and supplied by the supplier, and may not contain sums or concepts unrelated to that good or service" (art. 1). Breaches are sanctioned under Law 24.240 (art. 2). In force on publication with a 30 day adaptation period (art. 3). The government announced that it applied from 11 October 2024 (argentina.gob.ar news, 11 October 2024). The Ministry of Economy reported charges against 95 companies in November 2024 and 94 more in December 2024, and said Law 24.240 art. 47(b) allows fines of up to ARS 2,130 million (US$1,361,979.67) (news of 11 November and 20 December 2024) (unconfirmed). ENRE Res. 708/2024 (BO 8 October 2024) is listed by Infoleg as complementing Res. SIC 267/2024 for Edenor and Edesur.

Court challenge. On 21 February 2025 the government announced that the federal court in San Martín had rejected the amparo actions of seven PBA municipalities (Tigre, Hurlingham, Moreno, General Rodríguez, José C. Paz, Ituzaingó and San Martín) against Res. SIC 267/2024, and gave them 90 days to set up separate ways to collect their fees (argentina.gob.ar news, 21 February 2025). That is a first instance decision described in a government press release; appeals and later rulings were not found (unconfirmed).

Res. SE 259/2024 (BO 17 September 2024). Fuel stations in jurisdictions whose municipalities apply road or municipal fees on fuel prices must display at each pump a sticker reading "En esta jurisdicción se aplican tasas viales y/o municipales sobre el precio de los combustibles. Para más información, podrá consultar la página web de la Secretaría de Energía" (art. 3), with a 120 day adaptation period counted from entry into force (art. 6); the resolution took effect the day after publication (art. 7). Breaches are sanctioned under art. 15 of Res. SE 1104/2004 as replaced (art. 5). Fuel station owners told the Ministry on 19 September 2024 that some municipalities require them to collect local fees on fuel tickets, which Res. SIC 267/2024 now forbids (argentina.gob.ar news, 19 September 2024).

Ministry of Economy note to provinces (8 January 2025) (see section B).

Portal de Transparencia Tributaria Municipal (17 December 2025). The Ministry of Economy published a "Municipal Tax Map" with bases and rates of selected fees. It is meant as a baseline to compare the changes municipalities make in their 2026 ordinances (argentina.gob.ar news, 17 December 2025). The portal page covers the TISH for financial entities, primary activities, industry and hypermarkets, plus road fees on fuel, and states that the data were taken from municipal websites as of 31 March 2025, based on the ordinances approved at the start of the year, without later changes (argentina.gob.ar/jefatura/tasas-municipales). The figures themselves load from an external spreadsheet that could not be downloaded under this guide's source rules. A public form lets anyone report a municipal fee (argentina.gob.ar/formularios/reporta-una-tasa).

Law 27.795. some secondary summaries suggested this law might be a 2025 or 2026 measure against municipal fees on invoices. It is not. Infoleg lists Law 27.795 as the Ley de Financiamiento de la Educación Universitaria y Recomposición del Salario Docente, dated 21 October 2025 in the search results. No national law on municipal fees on invoices was found; the measure is Res. SIC 267/2024.

What Res. SIC 267/2024 does not do. It governs what may appear on consumer receipts. It does not abolish any municipal fee, does not change who owes the TISH, and does not affect a company's own TISH liability as a taxpayer. It mainly hits fees that municipalities used to collect through third parties' bills (electricity, gas, fuel). Whether a retailer may show the TISH as a separate line on its own consumer tickets is doubtful under art. 1 (unconfirmed).

I. Other municipal charges a business meets

Municipal ordinances typically include many charges besides the commerce and industry fee (unconfirmed). The ones that matter most to businesses are:

Operating licence (habilitación) fee, paid once when premises are approved and again on changes of activity, area or owner. The licence matters beyond the fee: under CM art. 35, third sentence, it can decide which municipalities may tax 100% of the provincial base.
Advertising and publicity fees (derechos de publicidad y propaganda) on signs, billboards and displays, usually per square metre or per item. Córdoba City goes further and includes "any act intended to promote, publicise, encourage or display" an activity in the taxable event of its main contribution (CTM art. 231). That kind of wording was criticised by the CSJN as too broad (Banco de Galicia).
Occupancy of public space (ocupación o uso del espacio público): tables and chairs on sidewalks, kiosks, containers, and the networks of utilities and telecom companies under or over streets (unconfirmed).
Road and fuel fees (tasas viales): charges on fuel sales or on rural land for road maintenance. Res. SE 259/2024 targets the fuel version; the Pacto Federal 1993 recommended capping the land version.
Property related fees (street lighting, cleaning and maintenance, often called ABL or servicios generales) on each property, paid by the owner or passed on to tenants by contract.
Building permits and construction duties for new plants or works (unconfirmed).
Health and food inspection fees, environmental fees, and fees on specific activities (slaughterhouses, transport, entertainment) (unconfirmed).

Each of these is a tasa and is subject to the same CSJN tests (real service, proportionality). Fees on networks and on public space can be easier for municipalities to defend because the use of public property is concrete; this page does not analyse that line of cases (unconfirmed).

J. CABA

The CABA collects gross income tax and other taxes directly; there is no second, municipal layer below it. some secondary summaries states that the City has no TISH because gross income tax replaces it. That explanation could not be checked against the CABA Código Fiscal (unconfirmed). What the sources do show:

Constitution art. 129 gives the City an autonomous government with its own legislation.
In 1993 the Nation (then responsible for the old Municipality of the City of Buenos Aires) committed to "reformulate the taxes collected by the Municipality of the City of Buenos Aires in the same sense and terms" as the provinces (Pacto Federal 1993, clause SEGUNDO 1)).
CABA was a party to Consenso 2017, so clause III(r) (single system to assess and pay municipal fees) mentioned "each province and the CABA".

For planning, a business with its head office in the CABA and stores in the PBA should expect no City fee on its CABA turnover equivalent to the TISH, but should check the City's fees on advertising, public space and property services (unconfirmed).

K. Contested and uncertain points (stated plainly)

Whether a municipality can charge a business with no premises. CM art. 35 third sentence assumes that some local laws require premises; others do not. The CSJN has invalidated charges where no service is shown (Raffo, Concordia, Western Union), but there is no single rule that "no premises means no fee" written in a statute. Municipalities argue that services such as inspecting products, sales points or advertising count. The outcome depends on the ordinance wording and on proof.
Whether the fee can be measured on income from other municipalities. Esso (2021) said that including income from municipalities where the company had no licensed premises was part of the proportionality problem. CM art. 35 third sentence allows licensed municipalities to share 100% of the provincial base when local law requires premises. Reconciling the two is still argued case by case.
Córdoba City's main contribution after Banco de Galicia (2026). The CSJN has now struck down the same CTM art. 231 wording three times (Raffo, Syngenta, Banco de Galicia). The rulings bind only the parties, and whether the City has since amended art. 231 or its practice is unknown (unconfirmed). Expect continued assessments and litigation.
The PBA courts versus the CSJN. The PBA Supreme Court held that proportionality is not required and that occasional inspections suffice. Mutual Pergamino (2026) rejected both views. PBA municipalities may keep applying their ordinances until each case is litigated.
Res. SIC 267/2024. Its legal basis is consumer law, not tax law. Municipalities argue it invades their autonomy; a first instance federal court disagreed (February 2025). The final outcome is open (unconfirmed).

Step by step

1. Map your municipal footprint before you sign a lease

List every place where you will have premises, staff, inventory, signs or vehicles: stores, offices, warehouses, plants, showrooms, kiosks inside third party shops, and sales staff working from home. For each, note the municipality (not just the province). Municipal boundaries in large metropolitan areas do not match city names; a "Rosario" warehouse may be in a neighbouring municipality. The choice of registered office (IGJ in the CABA or a provincial registry) does not decide where municipal fees are owed; see IGJ vs provincial registries.

2. Get the ordinances and check the numbers

For each municipality, obtain the current Ordenanza Fiscal and Ordenanza Tarifaria/Impositiva (most municipalities publish them on their websites) and the Ministry of Economy portal entry where available. Check: the name and taxable event of the fee, the base (gross income, area, employees, fixed amount), the rate for your activity code, minimums per premises, filing frequency, whether the fee requires premises (relevant for CM art. 35), exemptions, and the advertising and public space fees that apply to your signage.

3. Obtain the operating licence (habilitación)

File with the municipality's licensing office, usually with a title or lease, plans, fire safety and technical certificates, and the company's tax registration (CUIT and gross income registration). Pay the licence fee. Time and fee vary by municipality and risk level (unconfirmed). Register as a taxpayer of the commerce and industry fee at the same time, or within the deadline set by the ordinance (unconfirmed).

4. Compute the base every period

Single jurisdiction taxpayer (all activity in one province): the base is the gross income attributable to the municipality under the ordinance.
CM taxpayer: take the gross income base attributed to the province in your CM return (form CM03 or CM05 through SIFERE; see the gross income page). Then split it among the municipalities of that province using a municipal coefficient built from income and expenses in each municipality over the provincial totals (RG CA 106/2004 TA art. 6). If the local law requires premises, the municipalities where you hold a licence share up to 100% of the provincial base (CM art. 35, third sentence).

5. File and pay

File returns and pay through each municipality's online system at the frequency the ordinance sets (monthly or bimonthly is common) (unconfirmed). Keep a reconciliation between the municipal bases and the CM return; municipalities audit by comparing their base with the provincial returns.

6. Keep evidence of the service (or its absence)

Keep a log of every municipal inspection: date, inspector, act number and subject. After Mutual Pergamino (2026), the absence of regular inspections over many years is relevant evidence if you later challenge the fee. Do not create false evidence either way; keep official documents.

7. Check consumer invoices

If you sell to consumers, make sure receipts show only your goods or services and the national taxes that must be itemised under Law 27.743 art. 99. Do not add municipal charges as separate lines unless counsel confirms this is allowed (Res. SIC 267/2024 art. 1) (unconfirmed). If you are a utility or fuel station that municipalities use as a collector, review the conflict between the ordinance and Res. SIC 267/2024 with counsel.

8. If you receive an assessment

Read the act and calendar the deadlines. Note the local deadline for an administrative appeal; the same deadline governs filing a caso concreto with the Comisión Arbitral (RG CA 106/2004 TA art. 3).
Choose the route.
Base split or attribution disputes (CM): file a caso concreto with the Comisión Arbitral, attaching the inspection file, the act, the provincial returns for the audited years and all evidence (TA arts. 3 to 5).
Validity of the fee itself (no service, catch all definition, disproportion, double charge): administrative appeal before the municipality, then the provincial administrative courts, then the provincial supreme court, then an extraordinary appeal to the CSJN under Law 48 art. 14 (the route used in Banco de Galicia and Mutual Pergamino).
Raise everything at the first opportunity. In Banco de Galicia the Córdoba High Court refused to consider a statute of limitations defence first raised in court, because it was not raised in the administrative stage (concurring vote cons. 2). Raise limitation, proof of service, proportionality and the CM base in your first administrative reply.
Ask for proof. Deny that the service was provided and require the municipality to prove it (Quilpe, Gasnor, Mutual Pergamino). Ask for the municipality's data on total fee collections and the cost of the inspection service; in Mutual Pergamino the lower court's refusal of that request was part of the problem.
Avoid forum games. Do not try to stop a final provincial judgment through federal injunctions (Diarco, 2025).
Weigh time and cost. Supreme Court cases take a decade or more (Cost to do it, above). Many businesses pay under protest and then sue for a refund (repetición) (unconfirmed).

Costs and timelines

Table 1. The commerce and industry fee in the municipalities named in some secondary summaries

The rates below could not be read from any ordinance available under this guide's source rules. The table gives what the sources confirm and marks everything else.

Municipality (province)	Name of fee	Base	Rate 2026	Minimums / filing	Confirmed facts in sources
Córdoba City (Córdoba)	Contribución que incide sobre la actividad comercial, industrial y de servicios	Gross income, CM technical rules (CTM art. 232)	(unconfirmed)	(unconfirmed)	CTM art. 231 (Ord. 10.363) wording; fines 50% to 200% (CTM art. 101, old periods) (unconfirmed); CSJN struck down the charge in Raffo (2009), Syngenta (2013), Banco de Galicia (2026)
Rosario (Santa Fe)	Derecho de Registro e Inspección (unconfirmed)	Gross income (unconfirmed)	(unconfirmed)	(unconfirmed)	None in sources; the commonly cited "Municipalidad de Rosario c/ Esso" case was not found (see Table 5)
La Plata (Buenos Aires)	TISH (unconfirmed)	(unconfirmed)	(unconfirmed)	(unconfirmed)	None in sources
Pilar (Buenos Aires)	TISH (unconfirmed)	(unconfirmed)	(unconfirmed)	(unconfirmed)	None in sources
Tigre (Buenos Aires)	TISH (unconfirmed)	(unconfirmed)	(unconfirmed)	(unconfirmed)	One of seven municipalities whose amparo against Res. SIC 267/2024 was rejected (news, 21 February 2025)
Mendoza City (Mendoza)	(unconfirmed)	(unconfirmed)	(unconfirmed)	(unconfirmed)	None in sources
Merlo (Buenos Aires)	TISH	Inspection of premises	n/a	n/a	Ord. 1812/00, amended by Ord. 2187; Western Union (2025)
Pergamino (Buenos Aires)	TISH	Gross income	n/a	n/a	Ordenanza Fiscal arts. 85, 87, 88, 94 (t.o. 2009); ARS 8,523 per month paid by a mutual in 2015 (US$5.45 at today's rate, which says nothing about 2015 value)
La Matanza (Buenos Aires)	TISH	(unconfirmed)	n/a	n/a	Apremio judgment for ARS 23,108,513.17 for 12/2002 to 2004 (Diarco)
Quilmes (Buenos Aires)	TISH	Gross income including other municipalities	n/a	n/a	Esso (Fallos 344:2123)

Table 2. Limits and thresholds

Limit	Rule	Amount or test	Source
Base cap for CM taxpayers	Municipality may tax only the provincial share of gross income	Provincial CM coefficient × total base	CM art. 35, first sentence
Split among municipalities	Income and expenses in each municipality over the provincial total	Unified municipal coefficient × provincial base	RG CA 106/2004 TA art. 6
Licensed premises rule	Where local law requires premises, licensed municipalities share	Up to 100% of provincial base	CM art. 35, third sentence
Global collections	Fee collections must track cost	"For example up to double" the cost of the service	Mutual Pergamino (2026), cons. 15
Individual burden	No exorbitant charge on one taxpayer	Case by case	Mutual Pergamino, cons. 15
Road fees on land (1993 recommendation)	Not binding	0.40% of 80% of market value of suburban land	Pacto Federal 1993, PRIMERO 5)
Consumer law fines	Law 24.240 art. 47(b)	Up to ARS 2,130 million (US$1,361,979.67) per the Ministry's news	News of 11 November and 20 December 2024 (unconfirmed)
Córdoba City fines (historic)	CTM art. 101	50% to 200% of omitted amount	Banco de Galicia, concurring vote cons. 2 (unconfirmed)

Table 3. Deadlines

Step	Deadline	Source
Comisión Arbitral caso concreto against a municipal assessment	Within the period local law allows to appeal before the municipality	RG CA 106/2004 TA art. 3
Res. SIC 267/2024 adaptation	30 days from BO publication (11 September 2024); applied from 11 October 2024	Res. SIC 267/2024 art. 3; news 11 October 2024
Res. SE 259/2024 pump stickers	120 days from entry into force (the day after BO publication of 17 September 2024)	Res. SE 259/2024 arts. 6 and 7
Companies charged under Res. SIC 267/2024	5 business days to file a defence after notice	News 11 November and 20 December 2024
Municipalities after the San Martín ruling	90 days to set separate collection methods	News 21 February 2025
Monthly or bimonthly TISH returns and payments	Set by each ordinance	(unconfirmed)
Administrative appeal against a municipal assessment	Set by each ordinance or provincial procedure law (commonly 15 days)	(unconfirmed)

Table 4. Timeline of norms (with BO dates)

Date (BO)	Norm	Relevance
18 Aug 1977	Convenio Multilateral	Art. 35 limits municipal fees to the provincial share
Sanctioned 7 Jan 1988, promulgated 22 Jan 1988	Law 23.548	Art. 9(b): no analogous local taxes; fees for services actually rendered allowed
12 Aug 1993 signed; BO 25 Jan 1994	Pacto Federal para el Empleo, la Producción y el Crecimiento, ratified by Decree 14/1994	PRIMERO 2) and 5): promote repeal of fees without service or above cost; road fee cap recommendation
1994	Constitutional reform	Art. 123 municipal autonomy; art. 75(30); art. 129 CABA
2004 and 2005	RG CA 106/2004 and RG CA 113/2005	Municipal coefficient and caso concreto
16 Nov 2017 signed; BO 2 Jan 2018	Consenso 2017, Law 27.429	Clause III(p), (q), (r) on municipal fees
BO 12 Feb 2020	Consenso 2019, Law 27.542	Suspended other Consenso 2017 clauses, not (p) to (r)
BO 7 Jul 2021	Consenso 2020, Law 27.634	Extended suspension to 2021, not (p) to (r)
27 Dec 2021 signed; BO 4 Oct 2022	Consenso 2021, Law 27.687	DECIMOSEXTA: earlier provincial commitments dropped unless fulfilled
BO 8 Jul 2024	Law 27.743, Title VII	Price transparency; invitation to show provincial and municipal taxes
BO 11 Sep 2024	Res. SIC 267/2024	No third party charges on consumer receipts
BO 17 Sep 2024	Res. SE 259/2024	Pump stickers where municipal fuel fees apply
BO 8 Oct 2024	ENRE Res. 708/2024	Complements Res. SIC 267/2024 for electricity bills (Edenor, Edesur)
8 Jan 2025 (news)	Ministry of Economy note to provinces	Request to repeal disproportionate fees; possible suspension of revenue sharing
21 Oct 2025 (Infoleg date)	Law 27.795	University financing; not a municipal fee law
17 Dec 2025 (news)	Portal de Transparencia Tributaria Municipal	Public map of selected fees (data as of 31 Mar 2025)

Table 5. Supreme Court rulings on municipal fees used in this page

Case	Date	Holding relevant here	Source file
Compañía Química (Fallos 312:1575)	1989 (unconfirmed)	Broad, generic fee definitions; cited as basis of the doctrine	Cited in Banco de Galicia
Municipalidad de Concordia c/ Nación AFJP	26 Mar 2009	Doctrine applied in Western Union to activity without own premises	Cited in Western Union
Laboratorios Raffo c/ Municipalidad de Córdoba (Fallos 332:1503)	2009 (unconfirmed)	Concrete, effective, individualised service required	Cited in Banco de Galicia; Córdoba High Court remand 1 Oct 2010
Quilpe (Fallos 335:1987)	9 Oct 2012	Municipality must prove the service	SAIJ search; cited in Banco de Galicia
Syngenta Agro c/ Municipalidad de Córdoba	28 May 2013	Cannot save the fee by calling it a tax	SAIJ search; Banco de Galicia cons. 3
Gasnor c/ Municipalidad de La Banda (Fallos 344:2728)	7 Oct 2021	Residual "catch all" definitions invalid	SAIJ search; cited in Banco de Galicia
Esso Petrolera Argentina c/ Municipalidad de Quilmes (Fallos 344:2123 or 2133)	2021 (unconfirmed)	Gross income as base allowed if proportionate; income from other municipalities	Cited in Mutual Pergamino and Banco de Galicia
Diarco c/ Municipalidad de La Matanza	12 Mar 2025	Federal injunction against final provincial apremio overturned	csjn_2025_diarco_lamatanza_fallo
Western Union c/ Municipalidad de Merlo	10 Apr 2025	No double TISH for the same premises; agents' shops	csjn_2025_westernunion_merlo_fallo
La Gran Dulce c/ Municipalidad de La Matanza	25 Jun 2026	Leapfrog appeal inadmissible	csjn_2026_grandulce_lamatanza_fallo
Banco de Galicia c/ Municipalidad de Córdoba	10 Sep 2026	Córdoba contribution struck down a third time; burden on municipality	csjn_2026_galicia_cordoba_fallo
Mutual Pergamino c/ Municipalidad de Pergamino	10 Sep 2026	Periodic service; proportionality "up to double"	csjn_2026_mutual_pergamino_fallo
"Municipalidad de Rosario c/ Esso" (dólar MEP selling rate (dolarapi.com))	n/a	Not found in SAIJ; probably a confusion with Esso c/ Municipalidad de Quilmes	(unconfirmed)

Worked examples

All rates in these examples are illustrative assumptions chosen to show the mechanics. They are not the rates in the ordinances of Córdoba City, Rosario or any other municipality. Peso amounts are converted at ARS 1,563.90 per US$ (unconfirmed).

Example 1. Retailer with stores in Córdoba City and Rosario, head office in the CABA

Facts (fiscal year 2026). An Argentine SA sells clothing in its own stores: three stores in Córdoba City and two in Rosario. It also has a warehouse in a municipality next to Rosario (call it "Municipality W", Santa Fe) and a small head office in the CABA. It is a CM taxpayer under the general regime (CM art. 2).

Total gross income: ARS 4,800,000,000 (US$3,069,249.95).
Income by jurisdiction (place of sale): Córdoba 60%, Santa Fe 40%, CABA 0%.
Computable expenses by jurisdiction: Córdoba 55%, Santa Fe 35%, CABA 10%.
Within Santa Fe: all income from Rosario; Santa Fe expenses 80% in Rosario and 20% in Municipality W.
Illustrative fee rates: Córdoba City 0.70%; Rosario 0.60%; Municipality W 0.50%. No minimums are binding.

Step 1. Provincial CM coefficients (CM art. 2: 50% income, 50% expenses).

Jurisdiction	Income share	Expense share	Coefficient = 0.5 × income + 0.5 × expenses
Córdoba	0.60	0.55	0.575
Santa Fe	0.40	0.35	0.375
CABA	0.00	0.10	0.050
Total	1.00	1.00	1.000

Step 2. Provincial bases.

Jurisdiction	Base ARS	Base US$
Córdoba: 4,800,000,000 × 0.575	2,760,000,000	1,764,818.72
Santa Fe: 4,800,000,000 × 0.375	1,800,000,000	1,150,968.73
CABA: 4,800,000,000 × 0.050	240,000,000	153,462.50

The CABA share carries gross income tax but, on the commonly cited premise, no TISH equivalent (unconfirmed).

Step 3. Split each provincial base among municipalities (CM art. 35, second sentence; RG CA 106/2004 TA art. 6).

Córdoba province: the only municipality with activity is Córdoba City. Its municipal coefficient is 1.0 (100% of Córdoba income and expenses). Base: ARS 2,760,000,000.
Santa Fe province:
Rosario: 0.5 × (Rosario income / Santa Fe income = 1.00) + 0.5 × (Rosario expenses / Santa Fe expenses = 0.80) = 0.90. Base: 1,800,000,000 × 0.90 = ARS 1,620,000,000 (US$1,035,871.86).
Municipality W: 0.5 × 0 + 0.5 × 0.20 = 0.10. Base: 1,800,000,000 × 0.10 = ARS 180,000,000 (US$115,096.87).

If the Santa Fe ordinances required licensed premises and the company held licences in both Rosario and Municipality W, CM art. 35 third sentence would let those two municipalities together tax 100% of the Santa Fe base, which they already do here.

Step 4. Annual fee.

Municipality	Base ARS	Illustrative rate	Fee ARS	Fee US$	Monthly average ARS
Córdoba City	2,760,000,000	0.70%	19,320,000	12,353.73	1,610,000
Rosario	1,620,000,000	0.60%	9,720,000	6,215.23	810,000
Municipality W	180,000,000	0.50%	900,000	575.48	75,000
Total	4,560,000,000		29,940,000	19,144.45	2,495,000

The total equals 0.62% of the company's turnover, on top of provincial gross income tax.

Step 5. What CM art. 35 saves. If Córdoba City applied its 0.70% to the company's total turnover (ARS 4,800,000,000) instead of the Córdoba share, it would claim ARS 33,600,000 (US$21,484.75), which is ARS 14,280,000 (US$9,131.02) more than the CM allows. Disputes of this kind go to the Comisión Arbitral as a caso concreto.

Step 6. Other local charges to add (not computed). Habilitación fees for five stores and one warehouse, advertising fees on store signs, and public space fees for any sidewalk displays (unconfirmed). Córdoba City's CTM art. 231 also covers acts that "promote, publicise... or display" the activity, so check whether signs are taxed separately or within the contribution (unconfirmed).

Step 7. Risk note. The Córdoba City contribution has been struck down three times by the CSJN, most recently in Banco de Galicia (10 September 2026), for its catch all wording. A taxpayer that pays it can consider a refund claim, but the rulings bind only the parties, the City may defend its current wording and practice, and the route takes years. Do not stop paying without advice; unpaid fees carry interest and fines (the Córdoba CTM allowed 50% to 200%) (unconfirmed).

Example 2. Challenging a fee where the company has no premises

Facts. A CABA based pharmaceutical distributor has no office, store or warehouse in Córdoba City. It sells to pharmacies in the City through two travelling representatives who live there and use their own cars, and it ships from a warehouse in the PBA. In 2026 Córdoba City issues an assessment for its commerce and industry contribution for 2023 to 2025, taking as base the whole gross income attributed to Córdoba province in the company's CM returns. Assume all of the company's Córdoba province sales and expenses relate to Córdoba City.

Total gross income: 2023 ARS 1,200,000,000; 2024 ARS 2,400,000,000; 2025 ARS 3,600,000,000 (total ARS 7,200,000,000, US$4,603,874.93).
Córdoba share in the CM returns: income 25%, expenses 8% (representatives' salaries and travel), coefficient 0.5 × 0.25 + 0.5 × 0.08 = 0.165 each year.
Illustrative rate claimed: 0.60%. Fine assumed within the 50% to 200% range of the old CTM art. 101 (unconfirmed). Interest not computed.

Step 1. Quantify the exposure.

Year	Total income ARS	Córdoba base (× 0.165) ARS	US$
2023	1,200,000,000	198,000,000	126,606.56
2024	2,400,000,000	396,000,000	253,213.12
2025	3,600,000,000	594,000,000	379,819.68
Total	7,200,000,000	1,188,000,000	759,639.36

Fee claimed: 1,188,000,000 × 0.60% = ARS 7,128,000 (US$4,557.84).
Fine at 50%: ARS 3,564,000 (US$2,278.92); at 200%: ARS 14,256,000 (US$9,115.67).
Exposure before interest: ARS 10,692,000 to 21,384,000 (US$6,836.75 to 13,673.51).

The base itself is consistent with CM art. 35 (the City claims only the provincial share). So the fight is about whether any fee is owed at all, not about the CM split.

Step 2. Build the defence.

No concrete, effective, individualised service. The company has no premises the City could inspect. The representatives work at customers' pharmacies, which are inspected and pay their own fee (Laboratorios Raffo; Western Union, where the concurring vote rejected a second TISH for the same premises).
Catch all wording. The CTM art. 231 description of services ("any other not paid by a special tribute") has been held invalid three times; the burden of proving the service therefore falls on the City (Banco de Galicia, cons. 6).
Proportionality. Ask the City for total collections of the contribution and the cost of the inspection services. If collections exceed "for example up to double" the cost, the fee fails the general test (Mutual Pergamino, cons. 15) (unconfirmed).
CM art. 35 third sentence. If Córdoba's municipal law conditions the levy on premises, a municipality where the company holds no licence cannot take part in the 100% split (unconfirmed).
Limitation. Raise any time bar in the first administrative reply, not later (Banco de Galicia, concurring vote cons. 2).

Step 3. Choose the forum and calendar it.

Administrative appeal to the City within the CTM deadline (unconfirmed).
Comisión Arbitral caso concreto only if there is also a dispute on the CM attribution (filed within the same local deadline; RG CA 106/2004 TA art. 3).
Then the Córdoba administrative chamber, the Córdoba High Court, and the CSJN by extraordinary appeal.

Step 4. Compare cost and time. On the illustrative numbers, the claim is about US$7,000 to 14,000 plus interest for three years, and it repeats every year the company keeps selling in the City. The Banco de Galicia case took about eighteen years from the 2008 assessment to the 2026 ruling. A business may decide to (a) litigate a test year, (b) pay under protest and claim a refund, or (c) restructure (for example, have customers order directly from the PBA warehouse) to reduce the City's arguments. Professional fees are not regulated in the sources (unconfirmed). A taxpayer that loses in the provincial courts should not seek federal injunctions against enforcement (Diarco).

Variant: PBA municipality. If the same facts arose in a PBA municipality with a TISH tied to inspection of premises, Western Union and Concordia are the closest precedents. Expect the municipality to argue that representatives, vehicles, signs or stock in customers' shops are "activity in the district"; the PBA Supreme Court has been more favourable to municipalities on proof and proportionality than the CSJN (Mutual Pergamino, cons. 3 and 4).

Practical traps

Assuming the CM caps everything. CM art. 35 caps the base, not the rate, minimums or fixed fees per premises, and it applies only to CM taxpayers.
Forgetting expenses create attribution. A head office or warehouse moves CM base into a jurisdiction even without sales there (Example 1: CABA 5%; Municipality W 10% of the Santa Fe base).
Licensing everything everywhere. Under CM art. 35 third sentence, where local law requires premises, a licence can give a municipality a share of the provincial base. Do not license premises you do not need, and close licences you no longer use (unconfirmed).
Agents and shop in shop arrangements. Municipalities target companies that operate inside other businesses. Western Union (2025) helps, but only where no distinct service is shown.
Raising defences late. Limitation and other defences not raised in the administrative stage may be lost (Banco de Galicia).
Relying on the PBA courts' tests. The CSJN rejected the PBA Supreme Court's "confiscation only" and "occasional inspection" tests in 2026. Raise the federal question early so the case can reach the CSJN.
Treating Res. SIC 267/2024 as abolishing fees. It only governs what consumer receipts may contain. Your own TISH remains due.
Listing municipal fees on consumer tickets. Doing so may breach Res. SIC 267/2024 art. 1 (unconfirmed).
Ignoring annual ordinance changes. Ordinances are revised every year; the national portal was set up to track 2026 changes against March 2025 data.
Expecting Supreme Court wins to apply to everyone. The rulings decide individual cases; municipalities may keep collecting from others.
Federal forum shopping. Diarco shows the cost: the injunction was overturned and the case sent back to the provincial courts.
Mixing up fees and taxes in contracts. Leases often pass property fees (ABL or servicios generales) to tenants; the commerce and industry fee is always the operator's own liability.
Mutuals and cooperatives. A national exemption (for mutuals, Law 20.321 art. 29) may not cover municipal fees if the ordinance excludes them; in Mutual Pergamino the lower courts read the exemption narrowly, and the CSJN did not need to decide the point.
Establishments of national utility. Operating inside a port, airport or the Mercado Central does not by itself exempt you from municipal fees (Constitution art. 75(30); Diarco procedural history).

Recent changes

8 July 2024. Law 27.743 Title VII (price and tax transparency for consumers) published; art. 99 invites provinces and the CABA to show local taxes in prices.
11 September 2024. Res. SIC 267/2024 published: no third party charges on consumer receipts; 30 day adaptation.
17 September 2024. Res. SE 259/2024 published: fuel pump stickers where municipalities levy fees on fuel.
8 October 2024. ENRE Res. 708/2024 published (Edenor and Edesur billing).
11 October 2024. Res. SIC 267/2024 applied in practice (government announcement).
11 November and 20 December 2024. Charges against 95 and then 94 companies for including fees on bills.
8 January 2025. Ministry of Economy note to the provinces on disproportionate municipal fees.
21 February 2025. Federal court of San Martín rejects amparos of seven PBA municipalities against Res. SIC 267/2024 (government announcement) (unconfirmed).
12 March 2025. CSJN Diarco: federal injunction against provincial TISH enforcement overturned.
10 April 2025. CSJN Western Union: TISH claim against a company working through agents' premises set aside.
17 December 2025. Portal de Transparencia Tributaria Municipal published.
25 June 2026. CSJN La Gran Dulce: leapfrog appeal in a La Matanza dispute inadmissible.
10 September 2026. CSJN Banco de Galicia (Córdoba City contribution struck down) and Mutual Pergamino (periodic service, "up to double" proportionality test).

Pending changes

Municipal responses to Banco de Galicia and Mutual Pergamino. Watch Córdoba City's 2027 Ordenanza Tarifaria and PBA municipalities' 2027 ordinances for changes to wording, base or rates (unconfirmed).
Appeals on Res. SIC 267/2024 and possible new national rules on municipal charges in bills (unconfirmed).
Provincial measures after the 8 January 2025 note, such as laws limiting municipal fees or conditioning revenue sharing (unconfirmed).
Updates to the national portal with 2026 ordinance data (unconfirmed).
A new federal tax sharing law under Constitution art. 75(2) and its sixth transitional provision has been pending since 1996; any reform could reshape local taxing powers (unconfirmed).
Comisión Arbitral and provincial agreements on intermunicipal distribution (CM art. 35, second sentence) (unconfirmed).

FAQ

1. Is the TISH a tax or a fee? Legally a fee (tasa): it must pay for a concrete, effective and individualised service such as inspection of your premises (Laboratorios Raffo, Fallos 332:1503; Law 23.548 art. 9(b)). In practice it is usually calculated on gross income, which is why it is often litigated as a disguised tax.

2. My company has no premises in a municipality. Can it still be charged? Municipalities often try, especially where you have staff, agents, vehicles or advertising there. The CSJN has rejected charges with no service shown (Raffo, Concordia, Western Union), and the municipality must prove the service if you deny it (Quilpe, Gasnor, Mutual Pergamino). There is no statute that says "no premises means no fee", so the answer depends on the ordinance and the facts.

3. How much of my turnover can a municipality use as the base? If you are a CM taxpayer, at most the share of your gross income attributed to that province, divided among the municipalities of that province by income and expenses (CM art. 35; RG CA 106/2004 TA art. 6). Where local law requires premises, the municipalities where you hold licences may share 100% of the provincial base.

4. What are the rates in Córdoba, Rosario, La Plata, Pilar, Tigre and Mendoza? They are set each year in each municipality's tariff ordinance. None of those ordinances could be read for this page (unconfirmed). The Ministry of Economy's municipal transparency portal shows selected rates based on March 2025 ordinances.

5. Does the CABA charge a TISH? According to some secondary summaries, no, because the City collects gross income tax directly and has no municipalities. This could not be confirmed in the City's Código Fiscal (unconfirmed). The City may still charge advertising, public space and property service fees.

6. Can the fee be much higher than the cost of the inspections? No, according to the CSJN. In Mutual Pergamino (2026) the Court said total collections should not exceed "for example up to double" the cost of the service, and no taxpayer may bear an exorbitant share. Proving it requires the municipality's budget and collection data.

7. Did the 2017 fiscal pact abolish abusive municipal fees? No. Provinces only promised to promote fees tied to real services, a public database and a single payment system (Consenso 2017 clause III(p) to (r)). Those promises were not suspended in 2019 and 2020 but were dropped by Consenso 2021 clause DECIMOSEXTA unless already fulfilled.

8. What did the national government change in 2024 and 2025? Res. SIC 267/2024 bans unrelated charges (such as municipal fees) on consumer receipts, including utility bills; Res. SE 259/2024 requires fuel stations to warn that municipal fees affect fuel prices; the Ministry of Economy asked provinces in January 2025 to rein in fees and launched a transparency portal in December 2025. None of these abolished a municipal fee.

9. Is Law 27.795 about municipal fees? No. Infoleg lists it as the university education financing law (21 October 2025). The measure on fees in bills is Res. SIC 267/2024.

10. Where do I challenge a municipal assessment? Validity questions: administrative appeal to the municipality, then provincial courts, then the CSJN by extraordinary appeal. CM attribution questions: a caso concreto before the Comisión Arbitral, filed within the local appeal deadline (RG CA 106/2004 TA art. 3). Do not use federal injunctions to stop a final provincial judgment (Diarco).

11. Are municipal fees deductible for income tax? The Ministry of Economy's January 2025 note said municipal fees are deductible in computing income tax, which is one reason it argued they reduce shared revenue (news, 8 January 2025). Check deductibility against the Income Tax Law general deduction rule (unconfirmed).

12. Does the company's registry (IGJ or a province) affect municipal fees? No. The fees follow where you operate (premises and activity), not the registered office. See IGJ vs provincial registries. Stamp tax on your contracts follows its own rules; see Stamp tax.

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.