Argentina eliminates the mandatory disclosure regime (MDR)

  • On 21 October 2025, the Argentine Tax Authority published General Resolution No. 5772/2025, repealing the informative regime for certain international transactions (RICOI), effective immediately.
  • The repeal applies to fiscal years ending after 1 May 2025, eliminating the reporting requirements for companies, nonprofit entities, trusts, mutual funds and permanent establishments in Argentina regarding specific international transactions.
  • Previously, the RICOI mandated reporting for transactions with related foreign parties and those in non-cooperating or low-tax/no-tax jurisdictions, increasing compliance burdens for affected entities.
  • Affected entities should assess the implications of this repeal on their reporting obligations.

On 21 October 2025, the Argentine Tax Authority (ARCA) published General Resolution No. 5772/2025 (the Resolution) in the Official Gazette. The Resolution repeals General Resolution No. 5306/2022, which had established the informative regime for certain international transactions (RICOI or Régimen de Información Complementario de Operaciones Internacionales, in Spanish).

The Resolution entered into force on the date of its publication in the Official Gazette and will apply to the submission of information corresponding to fiscal years ending after 1 May 2025.

Publication of the Resolution eliminates the RICOI, which imposed reporting requirements on companies, nonprofit entities, trusts, mutual funds and permanent establishments incorporated or located in Argentina, for the following transactions:

  • Transactions performed with legal entities, trusts, permanent establishments or other parties domiciled, incorporated or located abroad, if they were related parties
  • Transactions performed with parties domiciled, incorporated or located in non-cooperating jurisdictions or low- or no-tax jurisdictions, even when carried out through their permanent establishments abroad

For background on the RICOI, see EY Global Tax Alert, Argentina implements new mandatory disclosure regime for international transactions, dated 4 January 2023.

Implications

Multinational entities with business operations incorporated or located in Argentina will want to take this repeal into consideration as they assess their reporting obligations.

For additional information concerning this Alert, please contact:

Pistrelli, Henry Martin & Asociados S.A., Buenos Aires

  • Carlos Casanovas 
  • Gustavo Scravaglieri 
  • Ariel Becher 
  • Sergio Caveggia 
  • Pablo Baroffio 
  • Sabrina Maiorano 
  • Juan Ignacio Pernin 

Ernst & Young LLP (United States), Latin American Business Center, New York

  • Pablo Wejcman 
  • Maria Paula Keller 
  • Ana Mingramm 
  • Enrique Perez Grovas 

Ernst & Young LLP (United Kingdom), Latin American Business Center, London

  • Lourdes Libreros 

Ernst & Young Tax Co., Latin American Business Center, Japan & Asia Pacific

  • Raul Moreno, Tokyo 
  • Luis Coronado, Singapore

For a full listing of contacts and email addresses, please click on the Tax News Update: Global Edition (GTNU) version of this Alert.

Published by NTD’s Tax Technical Knowledge Services group; Carolyn Wright, legal editor