Entities eligible for regularization • Subjects residing as of 12/31/2023. • Non-resident individuals who were Argentine tax residents until 12/31/2023.

Adhesion period • It will extend until 04/30/2025, inclusive. • The Executive Branch may extend the deadline until 07/31/2025.

Form of adhesion A manifestation of adhesion must be submitted, followed by a regularization tax return including the documentation and other information required through the regulations.

Regime Stages A specific tax rate will apply according to the stage of adhesion.

 

Stage Period to perform the manifestation of adhesion and the mandatory advance payment Deadline for the submission of the Tax Return and payment of the Regularization Tax Applicable Rate
1 From the day following the effective date of the respective regulations issued by AFIP until 09/30/2024, inclusive. 30/11/2024, inclusive. 5%
2 From 10/01/2024 until 12/31/2024, both dates inclusive. 31/01/2025, inclusive. 10%
3 From 01/01/2025 until 03/31/2025, both dates inclusive. 30/04/2025, inclusive. 15%

 

Regularization Date: In all cases, it will be 12/31/2023.  

Tax to be paid
• The amounts to be paid as Special Regularization Tax must be calculated and paid in U.S. Dollars.
• The tax to be paid will be calculated on the total value of the assets, both in Argentina and abroad, that are regularized.
• Special exclusion cases must be taken into account. The tax will be paid in U.S. dollars at the regularization exchange rate (*), according to the following scheme.

 

Stage 1

Total regularized tax base in U.S. Dollars Fixed tax in U.S. Dollars Rate On the excess of U.S. Dollars
0 a 100.000 0 0% 0
100.000 and above 0 5% 100.000

 

Stage 2

Total regularized tax base in U.S. Dollars Fixed tax in U.S. Dollars Rate On the excess of U.S. Dollars
0 a 100.000 0 0% 0
100.000 and above 0 10% 100.000

 

Stage 3

Total regularized tax base in U.S. Dollars Fixed tax in U.S. Dollars Rate On the excess of U.S. Dollars
0 a 100.000 0 0% 0
100.000 and above 0 15% 100.000

 

(*) Regularization Exchange Rate: must take as a reference the implicit exchange rate resulting from dividing the last quotation of a specific public security with settlement in Pesos in the price-time priority segment in BYMA (Bolsas y Mercados Argentinos, Argentina’s leading Stock Exchange) and the last quotation of said security with settlement in USD in the local jurisdiction, on the day prior to the Regularization Date (12/31/2023). The National Executive Branch may set said rate up to thirty percent (30%) above the official exchange rate published for the Regularization Date (12/31/2023) by the Central Bank of the Argentine Republic through Communication “A” 3500.

Assets to be regularized Assets in Argentina and abroad may be included, including real estate, shares, securities, crypto-assets (in the country), and other assets. Furthermore, special cases of exclusion from the tax base and payment of the Special Regularization Tax are provided for Cash, in Argentina or abroad, that is deposited or transferred to a Special Regularization Account; if it remains deposited until 01/01/2026, the date upon which any subsequent transfer would be exempt from the tax payment.

Release from actions and taxes Adhesion to the regime provides for the release from all civil actions and those related to tax, exchange, and customs crimes and administrative infractions that could correspond to the non-fulfillment of obligations linked to or originating from the declared assets, credits, and holdings, the income they may have generated, and the funds used for their acquisition. Likewise, they are released from the payment of Income Tax, Undocumented Outgoings Tax, Presumed Minimum Income Tax, Real Estate Transfer Tax (ITI), Internal Taxes, VAT, Tax on Credits and Debits, Wealth Tax (Bienes Personales), and the Extraordinary Solidarity Contribution.