Payments abroad: a tax-residence certificate replaces the sworn statement certified by the foreign tax authority

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 ↗

Jun 18, 2026. The resolution applies “15 days after” its publication in the Boletín Oficial, which was Jun 3, 2026. verif · Jun 18, 2026 ↗

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), Law 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 ↗