Argentine Tax Authority establishes new income tax prepayment for financial entities, insurance companies, payment service providers

Background

On 28 September 2023, the Argentine Federal Tax Authority (AFIP) published General Resolution No. 5424/2023 (the Resolution) establishing a new income tax prepayment for companies that provide "Financial Intermediation and Insurance Services" as their principal activity or that are registered as payment service providers.

General Resolution No. 5424

The Resolution establishes that the income tax prepayment must be paid by companies that meet both of the following requirements:

• They either provide Financial Intermediation and Insurance Services as their principal activity or are registered as payment service providers.

• Their taxable income determined for fiscal year 2022 or fiscal year 2023, as applicable, before the deduction of accumulated tax losses, is at least AR$600m1 (approximately US$1.7m).

The Resolution excludes from the new income tax prepayment entities subject to the income tax prepayment established by the GR 5391/20232 and those that obtained an income tax exemption certificate.

For purposes of determining whether the above thresholds are met, the Resolution clarifies which tax years taxpayers must take into account, specifically:

• Fiscal year 2022 when the year-end occurred between 1 August and 31 December 2022

• Fiscal year 2023 when the year-end occurred between 1 January and 31 July 2023

The amount of the income tax prepayment is determined by applying 15% on the net taxable income of the abovementioned fiscal periods, as applicable, without considering the deduction of accumulated tax losses.

The income tax prepayment will be creditable against the corporate income tax liability determined in the following fiscal years:

• Fiscal year 2023 for taxpayers with a year-end between 1 August and 31 December 2022

• Fiscal year 2024 for taxpayers with a year-end between 1 January and 31 July 2023

The income tax prepayment will be paid in three equal, consecutive monthly installments. The due dates will depend on the month of the year-end; for example, for fiscal years ended between August 2022 and April 2023, the first due date is 23 October 2023.

For additional information with respect to this Alert, please contact the following:

Pistrelli, Henry Martin & Asociados S.R.L., 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 Melina Oyhenart

• Ana Mingramm

• Lucas Moreno

• 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

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

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