Withholdings, perceptions and non resident rates
Last verified: 24 Oct 2026 · Status: Changing
Argentina relies heavily on withholding (retenciones) and advance collection (percepciones) regimes. Payments to non residents bear final income tax withholding under article 104 of the Income Tax Law, using a presumed net income percentage times 35%. Treaty rates require a residence certificate under ARCA RG 5855/2026 from 17 Jun 2026.
Key rules
| Payment to a non resident | Effective rate | Basis |
|---|---|---|
| Dividends | 7% | Income Tax Law, dividend withholding articles |
| Interest on loans from foreign banks, or from treaty jurisdictions or cooperating countries in specified cases | 15.05% | Art. 104: 43% presumed net income times 35% |
| Other interest | 35% | Art. 104: 100% presumed net income |
| Technical assistance and services under the Technology Transfer Law, not available locally | 21% | Art. 104: 60% times 35% |
| Patents and trademark royalties under the Technology Transfer Law | 28% | Art. 104: 80% times 35% |
| Other payments not specified | 31.5% | Art. 104: 90% times 35% |
- Treaty relief. A lower treaty rate applies only if the beneficiary proves residence. ARCA RG 5855/2026 (published 3 Jun 2026) replaced RG 3497: the certificate is valid 12 months when it states no term, must be apostilled under Law 23.458 or legalised unless the issuing authority allows electronic verification, and must be presented with an annex sworn statement before the first payment. It applies to payments from 17 Jun 2026.
- Withholding procedure. The payer withholds and remits under RG 739 and files the information return.
- Domestic regimes. Income tax withholdings on payments to residents (RG 830), VAT withholdings and collections, and provincial gross income withholdings including SIRCREB on bank credits. See the gross income pages.
Step by step
- Classify the payment under article 104 or the specific article.
- Check whether a treaty applies. Collect the residence certificate and sworn statement before the first payment.
- Withhold at payment or crediting, whichever comes first.
- Remit and report through ARCA's SICORE system.
- Keep the certificate file for audit.
International comparison
| Jurisdiction | Withholding on interest paid abroad (domestic law) |
|---|---|
| Argentina | 15.05% or 35% source |
| US (Delaware) | Not yet sourced |
| UK | Not yet sourced |
| Canada | Not yet sourced |
| Chile | Not yet sourced |
| Uruguay | Not yet sourced |
| Brazil | Not yet sourced |
| Singapore | Not yet sourced |
| Estonia | Not yet sourced |
Practical traps
- Grossing up: if the contract makes the local payer bear the tax, the base is grossed up, raising the cost.
- Royalties and technical assistance only get the 21% or 28% presumption if the contract is registered under the Technology Transfer Law 22.426 where required.
- An expired or unapostilled certificate means full domestic withholding.
Recent changes
- 17 Jun 2026. RG 5855/2026 residence certificate procedure applies to payments from this date.
The table summarises article 104. Conditions for 15.05% interest and the technology transfer cases are narrower than shown. Read the text before applying a rate.