Argentina

Taxable period

Tax is assessed on a fiscal-year, self-assessment basis, which may or may not match the calendar year.

Tax returns

The due date for filing the CIT return is during the second week of the fifth month after the fiscal year-end. Tax returns are filed electronically.

Payment of tax

Instalment payments on account of CIT must be made in the course of the tax year. The instalment payments must be made on a monthly basis, beginning in the first month after the due date of filing of the tax returns.

Penalties

Penalties derived from tax infractions may be applied by tax authorities, as follows (amounts as of 2026 which are updated on a yearly basis):

• Failing to file the tax return: Fines range between ARS 440,000 and ARS 67,500,000.
• Tax omission: Fine of 100% of unpaid taxes.
• Tax avoidance: Fines range between two and six times the avoided tax.
• Certain tax infractions may be penalised by closing the business premises for two to six days. In addition, fines ranging between ARS 200,000 and ARS 7,500,000 may be imposed.
• Simple evasion: Entities or individuals evading payment of social security contributions or withholdings, or both, payable to the tax authorities under the social security regime, through deceitful declarations, malicious concealment, or any fraudulent or deceitful procedure, either through action or omission, in excess of ARS 7,000,000 per fiscal period, shall be punished with two to six years’ imprisonment. Such amount will be ARS 100,000,000 in the case of taxes, it being applied by tax and by fiscal year.
• If the infringement qualifies as aggravated evasion: Imprisonment could be extended from three years and six months to nine years in certain situations.

Interest on late payments

Late payment of taxes is subject to compensatory interest. The applicable rate is periodically updated by the tax authorities (currently 2.75% monthly). Interest will start accruing on the day after the filing due date.

Tax audit process

The tax authorities are entitled to audit taxpayers within the statute of limitations period. Audits consist of revising the calculation of any national or provincial tax based on formal requirements. Where any assessment is issued by the tax authorities, the taxpayer is entitled to either accept it or file a claim. Assessments can be done under a real or estimated basis, depending on the specific case and the information that the taxpayers have on their transactions. In the case that the taxpayers do not accept the assessment during the administrative period, they can claim against Tax Courts before any judicial process.

There are no specific provisions about e-auditing.

Statute of limitations

The actions and powers of the tax authorities to determine and require payment of federal taxes, and to implement and enforce fines and closures planned, prescribe:

• After 5 years in the case of registered taxpayers, as well as in the case of unregistered taxpayers who are not legally obligated to register with the Tax Authorities or who, having such an obligation and not having fulfilled it, spontaneously regularize their situation. This period is reduced to 3 years when the registered taxpayer has complied in a timely manner with the filing of the corresponding tax return and, where applicable, has regularized the resulting balance, provided that the Tax Authority does not challenge such a tax return filed due to detecting a significant discrepancy between the information declared and the information available in its systems or provided by third parties, and
• ten years in the case of unregistered taxpayers.

Topics of focus for tax authorities

Topics of focus for tax authorities include the following:

• Increasing cooperation: Tax information exchange.
• Tax treaty network still under review.
• Tax treaty benefits: Substance-over-form principle.
• High penalties and tax criminal law.
• Transfer pricing (inter-company charges and export of commodities to international intermediaries).
• Wealth tax: Applicability on branches.
• Corporate income tax: Application of inflationary adjustment.