Argentina implements installment plan for corporate income tax obligations

• Through General Resolution No. 5,684, published in the Official Gazette on 30 April 2025, the Argentine Tax Authority has established an installment plan for the cancelation of the balance of an entity's corporate income tax (CIT) and its interest.
• This plan is mainly intended to amend the incorrect calculation of net operating losses (NOLs), either due to errors in their computation or in their update.
• Through this measure, the Argentine Tax Authority reinforces its position against adjustments for inflation of NOLs.

Through General Resolution No. 5,684, published in the Official Gazette on 30 April 2025, the Revenue and Customs Control Agency (abbreviated ARCA, in Spanish) has established an installment plan for the cancelation of the balance of an entity's corporate income tax and its interest, when net operating losses (NOLs) from previous years have been computed incorrectly, either due to errors in their computation or in their update, and the situation has been corrected by filing an amended tax return.

Taxpayers may adhere to this plan if they have:

1. Amended the corporate income tax (CIT) return corresponding to fiscal years due as of the effective date of the resolution to amend the incorrect calculation of NOLs from previous years
2. Filed the CIT return corresponding to the fiscal year ended between December 2024 and November 2025 considering the NOLs at historical values

Through General Resolution No. 5,688, published in the Official Gazette on 7 May 2025, ARCA clarified, among other things, that an entity's adherence to the installment plan will imply the waiver of an action and/or right of reimbursement for the periods and amounts included in the adherence.

Through these resolutions, the Argentine Tax Authority reinforces its position against adjustments for inflation of NOLs.