In focus
General considerations
Through Resolution No. 5424/2023 ("Resolution"), the Federal Tax Authority (FTA) implemented a new advance income tax applicable to Argentine companies engaged in (i) financial intermediation; (ii) insurance services; or (iii) payment services (companies that are payment service providers, also known as PSPs), that have obtained extraordinary income.
Subjects covered by the Resolution
The FTA determined that taxpayers must pay the advance income tax if the amount of the income tax arising from the tax returns corresponding to the fiscal year 2022 or 2023, without considering the deduction of tax losses from previous years, is equal to or higher than ARS 600 million.
To determine whether this new tax applies, the taxpayer must consider the income tax return for the 2022 tax period, if the closing of its business year took place between August and December 2022, both inclusive. Taxpayers whose fiscal year runs between January and July 2023, both inclusive, must consider the tax return corresponding to the 2023 fiscal year.
Taxpayers not covered by the Resolution
Taxpayers who have obtained an income tax exemption certificate during the tax periods 2022 and 2023 are excluded.
Allocation rules of the advance income tax
Taxpayers whose fiscal year ended between August and December 2022 shall allocate the advance income tax in the fiscal year 2023.
Taxpayers whose fiscal year ended between January and July 2023 shall allocate the advance income tax in the fiscal year 2024.
Calculation of the advance income tax
Taxpayers who have obtained a tax result for the year 2022 or 2023 equal to or higher than ARS 600 million, without considering the deduction of tax losses from previous years, are required to pay 15% of the tax result obtained.
Payment of the advance income tax
The Resolution establishes that the advance income tax, as well as its interest and other accessories, will be paid in three equal, deferred installments via electronic funds transfer through the FTA digital service "Presentación de DDJJ y Pagos" under the code "Tax-Concept-Subconcept:10-183-183."
Timeline for the payment of the advance income tax
The FTA established the following due dates for each installment of the advance income tax, according to the closing of the taxpayer's business year:
| Business year end |
Advance payment due date |
| Installment 1° |
Installment 2° |
Installment 3° |
| August 2022 to April 2023 |
23 October 2023 |
22 November 2023 |
22 December 2023 |
| May 2023 |
22 November 2023 |
22 December 2023 |
22 January 2024 |
| June 2023 |
22 December 2023 |
22 January 2024 |
22 February 2024 |
| July 2023 |
22 January 2024 |
22 February 2024 |
22 March 2024 |
If any of these dates fall on a nonbusiness day, the due date will be moved to the next business day.
Relevant characteristics of the advance income tax
The Resolution establishes that the advance income tax may not be canceled through tax compensation or be considered by the taxpayer in the estimate within the framework of the advance income tax reduction option.
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