Losses indexed to CPI, citizenship without tax residence

1) Tax losses are indexed to inflation (art. 190). It replaces the eleventh paragraph of article 25 of the Income Tax Law: «Losses generated in tax years beginning on or after 1 January 2025 shall be adjusted by the variation in the General Level Consumer Price Index (CPI) supplied by INDEC, over the period between the closing month of the tax year in which they arose and the closing month of the tax year being settled, without the first paragraph of article 93 of this law being applicable». In other words: the loss accumulated in one year keeps its real value until the year in which it is offset against a profit. 2) Fixed-term deposits are exempt in any currency (art. 191). In paragraph h) of article 26 — the list of exemptions — it replaces the phrase «fixed-term deposits in national currency» with «fixed-term deposits», with effect for tax years beginning on or after 1 January 2026. 3) Citizenship by investment does not drag in tax residence (art. 194). Three paragraphs are added to article 116: foreign individuals who obtained Argentine citizenship by naturalisation by virtue of having made relevant investments in the country, under paragraph 2 of article 2 of Citizenship Law No. 346, «shall not be considered tax residents… by the mere fact of that naturalisation», and for the purposes of paragraph b) of the same article «shall be considered individuals of foreign nationality». The exception is written into the third paragraph: anyone who was already a permanent resident in the country at the time of obtaining citizenship by investment remains a resident. verif · Mar 6, 2026 ↗

Each with its own date, and all three are written into the text. The indexation of losses reaches those generated in tax years beginning on or after 1 January 2025, meaning it looks back beyond the passing of the law. The fixed-term deposit exemption applies to tax years beginning on or after 1 January 2026. The article on citizenship by investment sets no date of its own, so it runs under article 217: from 6 March 2026. verif · Mar 6, 2026 ↗

The project that takes years to produce. A copper mine, a liquefaction plant, a transmission line: they build for three, five or seven years at a loss and only then start invoicing. With inflation, that accumulated loss was worth less and less by the time there was finally a profit to offset it against, which amounted to paying tax on a profit that was not real. Indexing losses to CPI restores that deduction to today's value. The foreign investor weighing up Argentine citizenship. Until now, naturalising could drag in Argentine tax residence, which taxes worldwide income. The article switches that off for anyone who obtained citizenship by investment and was not already a permanent resident. And anyone saving in foreign currency inside the system: fixed-term deposit interest is exempt regardless of currency. verif · Mar 6, 2026 ↗