In force since Jun 18, 2026
Payments abroad: a tax-residence certificate replaces the sworn statement certified by the foreign tax authority
ARCA GR 5855/2026 (Official Gazette June 3, 2026)
in forceNATIONAL
Market deregulation
RG ARCA 5855/2026 repeals RG 3.497 and 2.228: to use a double taxation treaty, a tax residence certificate is now enough.
The other rules on this subject40
Mega-DNU 70/2023: repeals the Rentals, Shelves and Supply lawsDecreto 70/2023 (DNU-2023-70-APN-PTE)in force
The IGJ digitizes companies' financial statementsIGJ General Res. 9/2026 (RESOG-2026-9-APN-IGJ#MJ), Official Gazette Jul 2, 2026in force
What changed and who it applies to
What changed
ARCA modernizes the procedure to apply the benefits of the Double Taxation Treaties (DTT) on payments of income abroad. It replaces GR 3.497 (DGI) and GR 2.228: it swaps the regime that required a sworn statement following a template, certified by the competent tax authority of the country of residence, for a system based on the valid tax-residence certificate issued by that authority, with a Hague Apostille or consular legalization. Key exception: if the beneficiary's country of residence has an official system of verification by electronic/digital means, the apostille is waived. It does not lower the underlying standard: it replaces the certification with a standard international instrument and admits the digital route. verif Jun 3, 2026 ↗
In force
Jun 18, 2026. The resolution applies “15 days after” its publication in the Boletín Oficial, which was Jun 3, 2026. verif Jun 18, 2026 ↗
Who it applies to
Foreign beneficiaries that receive Argentine-source income under a DTT (art. 102 of the Income Tax Law) and the paying parties/withholding agents (art. 6(f), Ley 11.683): companies that remit royalties, interest, dividends, fees or services abroad. It standardizes and speeds up the accreditation of tax residence to apply the treaty's reduced rate. verif Jun 3, 2026 ↗
The norm
Resolución General 5855/2026 of the Agencia de Recaudación y Control Aduanero (ARCA, the tax and customs agency), issued on Jun 2, 2026 and published in the Boletín Oficial on Jun 3, 2026 (notice 342732), effective 15 days after publication. It replaces RG 3.497 (DGI) and RG 2.228. verif Jun 3, 2026 ↗
Our reading
International tax simplification (R-desregulación): it replaces a certification procedure with a standard residence certificate (apostille) and enables digital verification, lowering the friction to apply the DTTs on payments abroad. It is a deregulation with an honest counterweight (it keeps the apostille except where digital verification exists), consistent with ARCA's simplification agenda. It eases operations for companies with cross-border flows. thesis
Analyze this rule for my company
Where it lands, province by province1
Neuquén The basin pays for technology abroad structurally: two service companies concentrate close to 70% of fracturing stages and operators remit services and royalties to their parents. Proving tax residence with an apostilled certificate — or without apostille where the country has digital verification — instead of a sworn statement certified by the foreign tax authority shortens the step that unlocks the treaty's reduced rate. favorable opening and deregulation thesis
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Analysis and curation: Ignacio Aredez
Head of Despegue
Method and track record →- 20+ years in technology, 15 of them in data and AI, for clients across Europe and the Americas
- Certified in AI governance (ISO/IEC 42001)
- Machine Learning (Google Cloud)
- Registered expert with the European Commission
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