Tax residence in Argentina for Pakistani taxpayers

Argentina does not count days: a foreigner becomes resident from the 1st day of the month after obtaining permanent residence or completing 12 months under temporary migration authorisations; trips away totalling up to 90 days in any 12-month period do not interrupt the period. Argentine citizens remain resident wherever they live until they lose that status. A resident pays Impuesto a las Ganancias on worldwide income and the annual wealth tax (Bienes Personales) on assets in Argentina and abroad. Pakistan counts its own tax year of 1 July – 30 June. There is no income tax treaty between Pakistan and Argentina, so dual residence is not resolved; each country credits the other's income tax under its own law (art. 165 LIG; s. 103).

Check your status: Pakistan and Argentina

Free, no sign-up, about 3 minutes. Conclusion under Pakistan's Income Tax Ordinance, 2001, compared with the law of Argentina and the tax treaty.

When Argentina treats you as a tax resident

Argentina determines the residence of individuals mainly by citizenship and migration status, not by a day count. An Argentine citizen is resident until he or she loses that status under art. 117 LIG; a foreigner becomes resident on obtaining permanent residence or after living 12 months under temporary migration authorisations.

A foreigner with permanent residence (residencia permanente) is an Argentine resident from the 1st day of the month after obtaining it, whatever the number of days in the country.

Without permanent residence a foreigner becomes resident after 12 months in Argentina under temporary migration authorisations. Trips away totalling up to 90 days in any 12-month period do not interrupt the period. Residence begins on the 1st day of the following month, so 12 months ending in December make you resident only from 1 January of the following year.

Art. 123 LIG excludes certain categories of foreigners from residence even after 12 months in Argentina: diplomatic and consular staff, representatives of international organisations, people staying for substantiated work reasons for no longer than 5 years, and students and researchers on scholarships. In addition, a foreigner without permanent residence may show ARCA in advance that his or her stay does not indicate an intention to reside permanently (art. 116 LIG, art. 281 Reglamentación).

An Argentine resident (citizen or foreigner) loses that status on obtaining permanent residence in another State or after 12 continuous months abroad (visits totalling up to 90 days in any 12-month period do not interrupt the period). The loss takes effect from the 1st day of the following month. Pakistani citizens who move to Pakistan obtain no permanent residence permit there, so the 12-month rule applies to them.

Loss of residence does not take effect for someone who, having become resident of another State, continues to live in Argentina or returns to live there: art. 122 LIG applies its own criteria for resolving dual residence (there is no treaty with Pakistan, so these criteria apply, art. 3 RG 4236).

The first test of art. 122: whether you keep a permanent home in Argentina — a dwelling continuously available to you (owned, rented or provided), not a dwelling for a short stay.

If you have a permanent home only in Argentina, you are its resident under art. 122 (a). If you have a home in both States, the centre of vital interests decides (art. 122 (b)).

The centre of vital interests is the State of the closest personal and economic relations taken together; if they are in different States, ARCA gives priority to personal relations (art. 3 RG 4236).

If the centre of vital interests cannot be determined, habitual abode decides: you are an Argentine resident if in the calendar year you stayed there longer than in the State of your other residence (art. 284 Reglamentación).

With equal stays in both States, only an Argentine citizen remains an Argentine resident (art. 122 (d)).

No days are counted for Argentine citizens: residence lasts until one of the grounds for loss under art. 117 LIG occurs.

In the year you obtain it, Argentina treats you as resident only from the 1st day of the following month; until then you are taxed as a non-resident.

Before residence begins, Argentine-source income is taxed as income of a non-resident (35% withholding on deemed net income).

Argentina splits the year: the status changes from the 1st day of the month following the event. Loss of residence must be proved to ARCA (art. 2 RG 4236, art. 25 RG 5803/2025).

The burden of proving the loss lies on the taxpayer (art. 2 RG 4236).

The conclusion is «probable», because ARCA will deregister you only once the evidence is filed; the loss occurs automatically by law, but administrative practice requires proof.

Art. 122 is a domestic Argentine rule; with no treaty with Pakistan it does not limit Pakistan's right to treat you as its resident.

The centre of vital interests is assessed on personal and economic ties taken together, with priority to personal ties (art. 3 RG 4236).

Time spent in the calendar year is compared (art. 284 Reglamentación).

The citizenship criterion of art. 122 works only in Argentina's favour: a citizen of another State with equal stays does not become an Argentine resident.

The order of criteria (a)–(d) of art. 122 is not reconciled with (b) in the law: read literally, (a) covers anyone with a permanent home in Argentina. We found no case law from official sources.

Clarify the facts about your home, centre of vital interests and days spent in both States.

For foreigners the number of days by itself does not matter: what matters is migration status and 12 months under temporary authorisations.

The law does not say how the rule of art. 116 inc. b) on 12 months under temporary migration authorisations applies to such citizens, who no longer need migration authorisations. If you actually live in Argentina, the conclusion may differ — get professional advice.

The exception applies only to foreigners who were not Argentine residents when hired or when they started work.

The law does not specify how the 5 years are counted or what happens after them; the work reasons must be documented. Hence the conclusion is «probable».

If you receive any other pay besides the scholarship, the exception does not apply.

The confirmation is filed only once. Under art. 281 (third paragraph) of the Reglamentación, if you stay on in Argentina after the period ends, the rules of art. 116 LIG on acquiring residence apply (the article refers to the last paragraph of art. 116); how this is applied in practice is not settled.

A foreigner's residence depends on migration status and the 12-month period, not on days in the calendar year.

You are an Argentine citizen and have not lost residence (you have not obtained permanent residence abroad and have not stayed outside Argentina continuously for 12 months) — you are an Argentine tax resident (art. 116 inc. a) LIG) whatever the number of days in the country. Argentina taxes your worldwide income (art. 1 LIG) and worldwide assets (Bienes Personales); it credits foreign income tax, including Pakistani tax, on foreign-source income up to its own tax (art. 165 LIG). There is no Pakistan–Argentina tax treaty.
You hold permanent residence in Argentina — you are an Argentine tax resident (art. 116 inc. b) LIG) from the 1st day of the month after obtaining it, whatever the number of days in the country. Argentina taxes your worldwide income (art. 1 LIG) and worldwide assets (Bienes Personales); it credits foreign income tax, including Pakistani tax, on foreign-source income up to its own tax (art. 165 LIG). There is no Pakistan–Argentina tax treaty.
You have lived in Argentina for 12 months under temporary migration authorisations and do not fall within the exceptions of art. 123 — you are an Argentine tax resident (art. 116 inc. b) LIG) from the 1st day of the month after the 12 months are completed. Argentina taxes your worldwide income (art. 1 LIG) and worldwide assets (Bienes Personales); it credits foreign income tax, including Pakistani tax, on foreign-source income up to its own tax (art. 165 LIG). There is no Pakistan–Argentina tax treaty.
You were an Argentine resident until the end of the month in which you obtained permanent residence abroad or completed 12 months abroad; from the 1st day of the following month you are a non-resident (art. 117 LIG). So in the selected year you are an Argentine resident for only part of the year: for that period Argentina taxes worldwide income, afterwards only Argentine income (35% withholding on deemed net income). If you nevertheless continue to live in Argentina, art. 122 LIG may keep you resident.
You were an Argentine resident, but it is not known whether you have lost that status. Until you can prove that you obtained permanent residence abroad or spent 12 continuous months outside Argentina (with visits totalling no more than 90 days in any 12-month period), ARCA will treat you as resident and expect returns on worldwide income.
You have lost Argentine residence and are treated as resident of another State, but you continue to live in Argentina and have a permanent home there, and none abroad. Under art. 122 (a) LIG you remain (or again become) an Argentine resident. Argentina taxes your worldwide income (art. 1 LIG) and worldwide assets (Bienes Personales); it credits foreign income tax, including Pakistani tax, on foreign-source income up to its own tax (art. 165 LIG). There is no Pakistan–Argentina tax treaty.
You have a permanent home both in Argentina and in the State of your other residence, and your centre of vital interests is in Argentina. Under art. 122 (b) LIG you remain (or again become) an Argentine resident. Argentina taxes your worldwide income (art. 1 LIG) and worldwide assets (Bienes Personales); it credits foreign income tax, including Pakistani tax, on foreign-source income up to its own tax (art. 165 LIG). There is no Pakistan–Argentina tax treaty.
Your centre of vital interests could not be determined, and in the calendar year you spent more time in Argentina than in the State of your other residence. Under art. 122 (c) LIG you remain (or again become) an Argentine resident. Argentina taxes your worldwide income (art. 1 LIG) and worldwide assets (Bienes Personales); it credits foreign income tax, including Pakistani tax, on foreign-source income up to its own tax (art. 165 LIG). There is no Pakistan–Argentina tax treaty.
Your centre of vital interests could not be determined, and your time in Argentina and in the State of your other residence is equal. As an Argentine citizen you remain (or again become) its resident under art. 122 (d) LIG. Argentina taxes your worldwide income (art. 1 LIG) and worldwide assets (Bienes Personales); it credits foreign income tax, including Pakistani tax, on foreign-source income up to its own tax (art. 165 LIG). There is no Pakistan–Argentina tax treaty.

When you are a nonresident

You have lost Argentine residence (you obtained permanent residence abroad or lived outside Argentina continuously for 12 months) and do not live in Argentina — from the 1st day of the month following that event you are a non-resident (art. 117 LIG). Argentina taxes only Argentine-source income (35% withholding on deemed net income, dividends — 7%) and assets in Argentina. The loss must be proved to ARCA, otherwise you will continue to be treated as resident.
You have lost Argentine residence and, although you continue to live in Argentina, the criteria of art. 122 LIG point to the State of your other residence (centre of vital interests or more time spent there, or you are not an Argentine citizen). You are then a non-resident of Argentina. The conclusion is disputed: art. 122 (a) literally names a permanent home in Argentina as sufficient, so ARCA may treat you as resident if you have kept a home there.
You are not an Argentine citizen, do not hold permanent residence and have not yet lived in Argentina for 12 months under temporary migration authorisations (or they end only in December) — in the selected year you are a non-resident of Argentina. Argentina taxes only Argentine-source income: 35% of deemed net income is withheld from payments (for example, from pay — 35% of 70%, i.e. 24.5%; if you stay in Argentina more than 6 months in the fiscal year — 35% of 90%, i.e. 31.5%), dividends — 7%.
You obtained Argentine citizenship by naturalisation for making significant investments in Argentina (art. 2 inc. 2 Ley 346) and did not hold Argentine permanent residence at that time. Since Ley 27.802 (published 6 Mar 2026), such naturalisation does not by itself make you an Argentine tax resident (art. 116 inc. a) LIG), and for art. 116 inc. b) you are treated as a foreigner — so this citizenship does not make you resident. Argentina taxes only your Argentine-source income (as a beneficiary abroad) and your assets located in Argentina.
As a staff member of a foreign diplomatic or consular mission or of an international organisation of which Argentina is a member (or a family member of such a person), you do not become an Argentine resident however long you stay (art. 123 inc. a)–b) LIG). Argentine-source income is taxed under the rules for residents. The pay of diplomats, consular agents and other official representatives of foreign countries for their functions is exempt, subject to reciprocity (art. 26 inc. c) LIG).
You are in Argentina for substantiated work reasons, and the stay does not exceed 5 years — under art. 123 inc. c) LIG you do not become an Argentine resident even after 12 months. Argentine-source income (including pay for work in Argentina) is taxed under the rules for residents, i.e. at the progressive scale rather than by 35% withholding. Argentina does not tax your foreign income.
You are in Argentina on a temporary authorisation for study or research and receive only a scholarship — while the authorisation lasts, you are not an Argentine resident (art. 123 inc. d) LIG).
You confirmed to ARCA in advance (no later than 30 days before the end of the 12-month period) that your stay is not connected with an intention to live in Argentina permanently — so 12 months under temporary authorisations do not make you resident (art. 116 LIG, art. 281 Reglamentación). However, if you stay on in Argentina after that period ends, the rules on acquiring residence apply (art. 281, third paragraph, Reglamentación) — you may become resident.

Where the rules of Argentina clash with Pakistani tax rules

Collision: resident of both countries — no treaty to decide. Argentina treats you as resident by citizenship, permanent residence or 12 months under temporary authorisations — without counting days; Pakistan by 183 days in its tax year (1 July – 30 June), a government posting abroad, or citizenship under s. 82(d). Without a treaty each country taxes your worldwide income, and Argentina also levies Bienes Personales on your worldwide assets. Argentina credits Pakistani income tax on income that is foreign-source for it, up to its own tax (art. 165 LIG); Pakistan credits Argentine tax on Argentine-source income (s. 103) and exempts Argentine salary on which Argentine tax was withheld and paid (s. 102). Argentina's domestic tie-breaker (art. 122 LIG) applies only to people who have lost Argentine residence and does not bind Pakistan. A Pakistani citizen with fewer than 183 days in Pakistan who spends more than 182 days in Argentina in the Pakistani tax year and is an Argentine resident taxpayer is no longer resident in Pakistan under s. 82(d).

What else to know

No income tax treaty between Pakistan and Argentina. Pakistan and Argentina have no treaty for the avoidance of double taxation: Argentina is not on FBR's list of Pakistan's full-scope treaties, Pakistan is not on the Argentine Ministry of Economy's list of treaties in force and does not appear on ARCA's list of countries with tax agreements. So no rule resolves dual residence, limits the taxation of pay or lowers the rates on dividends, interest and royalties, and there is no mutual agreement procedure. Double tax is relieved only by each country's own rules: in Argentina by a credit for similar foreign taxes on foreign-source income (art. 165 LIG, no treaty needed); in Pakistan by the credit for foreign tax (s. 103) and the exemption of foreign salary taxed at source (s. 102).
Argentine citizenship makes you resident without counting days. An Argentine citizen — including a dual Pakistani–Argentine citizen — remains an Argentine tax resident wherever he or she lives until obtaining permanent residence in another State or spending 12 consecutive months outside Argentina (visits totalling up to 90 days in any 12-month period do not interrupt the period). A Pakistani citizen who moves to Pakistan obtains no permanent residence permit there, so a dual citizen moving to Pakistan loses Argentine residence only under the 12-month rule. Until then Argentina taxes your worldwide income and assets, and Pakistan may tax you as a resident at the same time.
Working in Argentina: tax from the first day. Pay for work performed in Argentina has an Argentine source. No treaty exempts it for short stays, so a non-resident pays a final 35% tax on a deemed 70% of the payment (24.5%; if you stay in Argentina more than 6 months in the fiscal year — 35% of 90%, i.e. 31.5%) or on the other percentages of art. 104 LIG. In Pakistan, salary earned in Argentina is exempt if the Argentine tax on it was withheld by the employer and paid to the Argentine tax authority (s. 102); otherwise Pakistan gives a credit for the Argentine tax, limited to the Pakistani tax on that income (s. 103).
How double tax is relieved without a treaty. If you are resident in Pakistan, Argentine tax on Argentine-source income is credited against Pakistani tax on that income, computed separately for each head of income; unused credit is lost and the Argentine tax must be paid within two years after the end of the Pakistani tax year (s. 103). If you are resident in Argentina, similar taxes actually paid in Pakistan on foreign-source income are credited up to the Argentine tax on that income, and the excess is carried forward for 5 years (arts. 165–175 LIG). To prove the tax paid in Pakistan, ask the Competent Authority for a certificate of tax paid (rule 19B).
Year of moving: Argentina changes status from the 1st of the next month, Pakistan does not. Argentina does not determine residence for the calendar year: a foreigner becomes resident from the 1st day of the month after obtaining permanent residence or completing 12 months under temporary authorisations, and a resident loses the status from the 1st day of the month after obtaining permanent residence abroad or completing 12 months abroad. Pakistan decides your status for its whole tax year (1 July – 30 June). A Pakistani citizen who leaves Pakistan during a tax year and stays abroad for the rest of it is exempt in Pakistan on salary earned abroad in that year (s. 51(2)); a citizen who returns after four non-resident tax years is exempt on foreign-source income in the year of return and the next (s. 51(1)). Without a treaty there is no mutual agreement procedure to reconcile the periods.
How to end Argentine residence. Whoever relies on loss of residence must prove it: with a certificate of permanent residence in another State or with a passport, consular certificate or other document showing 12 months abroad (with a sworn translation and apostille). A Pakistani citizen moving to Pakistan gets no permanent residence permit there, so the proof is of the 12 months abroad. The documents are filed with ARCA through the «Sistema Registral» together with the application to deregister from Ganancias and Bienes Personales (codes 242 or 243); for Bienes Personales a substitute taxpayer must be appointed in Argentina. After losing the status, tell Argentine payers of income that you are a beneficiary abroad.
Wealth tax (Bienes Personales). An Argentine resident pays Bienes Personales every year on assets held on 31 December in Argentina and abroad, including a home, accounts and shares in Pakistan: for 2026 — 0.5% and 0.75% of the value above the tax-free minimum (ARS 100,000,000 in the law, indexed annually; the taxpayer's home is exempt up to ARS 350,000,000), from 2027 — 0.25%. A non-resident pays 0.5% only on assets in Argentina, through a substitute taxpayer. Bienes Personales is a tax on assets, not on income, so Pakistan's credit for foreign income tax (s. 103) does not cover it.
Non-resident taxed like a resident. Foreigners in Argentina as diplomatic staff, representatives of international organisations, for work reasons (up to 5 years) or for study on a scholarship are not residents, but their Argentine-source income is taxed under the rules for residents — at the progressive scale with a tax return, not by the final 35% withholding. Argentina does not tax their foreign income, including income from Pakistan.
From 2026: housing rent and sales of real estate in Argentina are exempt. Ley 27.802 (published 6 Mar 2026) exempted from Impuesto a las Ganancias income from letting housing for residential use for periods from 1 Jan 2026 and gains on real estate in Argentina sold from 1 Jan 2026; Decreto 406/2026 extended the exemption for sales of real estate to individuals — residents and non-residents. If you are resident in Pakistan, the Argentine exemption does not affect Pakistani tax on this foreign-source income, and with no Argentine tax there is nothing to credit under s. 103.
Pakistani government posting to Argentina. Federal and Provincial Government employees and officials posted abroad remain resident in Pakistan under s. 82(c), and their government salary is Pakistan-source income (s. 101). There is no treaty article reserving it to Pakistan; in Argentina, staff of foreign embassies and consulates are not residents (art. 123 LIG); how Argentina taxes their pay depends on Argentine law and diplomatic privileges, which this package does not model.

How dual residence is resolved

There is no tax treaty in force between Pakistan and this country.

Terms you will come across in Argentina

Impuesto a las Ganancias: income tax; residents pay it on worldwide income at 5–35%
LIG: Income Tax Act (Ley de Impuesto a las Ganancias, t.o. 2019); residence — arts. 116–123
ARCA: Argentina's tax authority; loss of residence must be proved to it
residencia permanente: permanent residence: makes you resident from the 1st day of the following month
Bienes Personales: annual wealth tax; residents pay it on assets in Argentina and abroad
responsable sustituto: substitute taxpayer in Argentina who pays Bienes Personales for a non-resident

Questions

Is there a tax treaty between Pakistan and Argentina?

No. Argentina is not on FBR's list of Pakistan's full-scope treaties, and Pakistan is not on Argentina's list of treaties in force. So nothing resolves dual residence, and Argentine withholding on pay, dividends, interest and royalties is not reduced. Argentina credits similar foreign taxes on foreign-source income without a treaty (art. 165 LIG); Pakistan credits Argentine tax (s. 103).

When does a foreigner become an Argentine resident?

With permanent residence, from the 1st day of the month after obtaining it, whatever the number of days. Under temporary migration authorisations, from the 1st day of the month after completing 12 months; trips away totalling up to 90 days in any 12-month period do not interrupt the period. Diplomatic staff, people in Argentina for work reasons for up to 5 years and scholarship students or researchers do not become residents.

How do I end Argentine residence when I move to Pakistan?

Residence is lost from the 1st day of the month after you obtain permanent residence abroad or complete 12 consecutive months outside Argentina (visits totalling up to 90 days in any 12-month period do not interrupt the period); a Pakistani citizen moving to Pakistan gets no permanent residence permit there, so the 12-month rule applies. You must prove the loss to ARCA and deregister from Ganancias and Bienes Personales; until then ARCA treats you as resident.

Sources

Legislation and official guidance

art. 116 inc. a)–b) Ley de Impuesto a las Ganancias (LIG), t.o. 2019 (Decreto 824/2019), as currently in force — Argentine residents are: (a) Argentine citizens (by birth or naturalisation), except those who have lost residence under art. 117; (b) foreigners who have obtained permanent residence in Argentina, or who, without it, have stayed in Argentina for 12 months under temporary authorisations provided for by migration law. Temporary absences within the limits set by the regulations do not interrupt the 12-month period. Resident status begins on the 1st day of the month following the month in which permanent residence was obtained or the 12 months were completed. A foreigner without permanent residence whose stay does not show an intention to reside permanently may substantiate the reasons in the manner set by the regulations. Under Ley 27.802 (published 6 Mar 2026, art. 194), a foreigner who obtained Argentine citizenship by naturalisation for making significant investments in Argentina (art. 2 inc. 2 Ley 346) is not resident under (a) merely because of that naturalisation; for (b) he or she is treated as a foreign national, and remains resident under (b) if already a permanent resident of Argentina when obtaining citizenship.
art. 281 Reglamentación LIG (Decreto 862/2019) — For art. 116 inc. b): temporary absences totalling no more than 90 days in any 12-month period (continuous or not) do not interrupt the continuity of the stay; days of absence are counted from the day after departure to the day of return inclusive. The reasons showing no intention to reside permanently are substantiated to ARCA once, no later than 30 days before the end of the 12-month period. If, after the confirmation, the foreigner stays on in Argentina after that period ends, the rules of art. 116 on acquiring residence apply (art. 281, third paragraph).
art. 123 LIG t.o. 2019 — The following are not residents, even after a long stay in Argentina: (a) members of foreign diplomatic and consular missions, their technical and administrative staff — foreigners who were not resident when hired — and their family members; (b) representatives and agents of international organisations of which Argentina is a member — foreigners — and their family members; (c) foreigners whose stay is due to substantiated work reasons, if the stay does not exceed 5 years, and their family members; (d) foreigners holding a temporary authorisation for study (secondary, higher or postgraduate education) or research whose only remuneration is a scholarship — while the authorisation lasts. Their Argentine-source income is taxed under the rules for residents.
art. 117–118 LIG t.o. 2019 — A resident loses that status when he or she (1) obtains permanent resident status in a foreign State under its migration law, or (2) without having obtained it earlier, stays outside Argentina continuously for 12 months; temporary visits within the limits set by the regulations do not interrupt this period. The loss takes effect from the 1st day of the month following the month in which foreign permanent residence was obtained or the 12 months were completed. People abroad as official representatives of the Argentine State, or performing functions entrusted by the State, the provinces, the municipalities or the City of Buenos Aires, do not lose residence through continuous absence (art. 118). A person absent for reasons that do not imply an intention to remain abroad habitually may prove this (art. 117, second paragraph) and then does not lose residence through the 12 months abroad; according to ARCA, this is proved to ARCA — the Reglamentación sets no time limit or form.
art. 283 Reglamentación LIG (Decreto 862/2019) — For art. 117: temporary visits to Argentina totalling no more than 90 days in any 12-month period (continuous or not) do not interrupt the continuous stay abroad; days are counted from the day after entry to the day of departure inclusive.
art. 122 LIG t.o. 2019; art. 284 Reglamentación (Decreto 862/2019) — People who have obtained permanent residence abroad or lost Argentine residence, are treated as residents of another State for tax purposes, but continue to live in Argentina or return to live there remain (or again become) Argentine residents if: (a) they keep a permanent home in Argentina; (b) having a permanent home both in Argentina and in the other State, their centre of vital interests is in Argentina; (c) if the centre cannot be determined — they habitually live in Argentina, i.e. stay there longer than in the other State (the calendar year is compared, art. 284 Reglamentación); (d) with equal stays — if they are Argentine citizens. This applies from the date residence was lost or from the 1st day of the month following the return.
art. 3 RG AFIP 4236/2018 (dual residence) — If there is a tax treaty with the other State, its rules apply; if there is none — a permanent home means a dwelling continuously available to the person whatever the legal title (owner, tenant, borrower), excluding short stays for travel, business, study or leisure; the centre of vital interests is the State of the closest personal and economic relations taken together, and if they are in different States, personal relations prevail.
art. 1 LIG t.o. 2019 — Residents pay tax on income from Argentine and foreign sources and may credit similar taxes actually paid abroad, up to the increase in Argentine tax caused by including the foreign income; non-residents — only on income from Argentine sources.
art. 119–121 LIG t.o. 2019; art. 2 RG AFIP 4236/2018 — Anyone relying on loss of residence must prove it: with a certificate of permanent residence from the competent authority of the foreign State, or with a passport, consular certificate or other reliable document showing departure and a stay abroad for the required period (with a sworn translation and apostille). From the date of loss the person is a «beneficiary abroad» for Argentine income and must inform the withholding agents (art. 120). The documents are attached to the application to deregister as a Ganancias taxpayer; until it is granted, all taxpayer obligations remain.
ARCA — «¿En qué casos se produce la pérdida de la residencia fiscal?» (Q&A on the Ley 27.743 regime) — Residence is lost from the 1st day of the month following the grant of foreign permanent residence or the completion of 12 months of continuous stay abroad; visits to Argentina totalling up to 90 days in any 12-month period do not interrupt this period. For people who became residents within the Ley 27.743 asset regularisation regime, the loss cannot occur before 1 Jan 2025 (art. 4 Decreto 608/2024).
art. 25 RG ARCA 5803/2025 (in force from 2 Mar 2026) — To deregister from Ganancias and/or Bienes Personales on loss of residence (art. 117 LIG), the person declares in the «Sistema Registral» a foreign address («Domicilio del exterior») and residence abroad, attaches PDF copies of the evidence under art. 2 RG 4236 and selects the reason code: 242 — permanent residence acquired in another jurisdiction, 243 — continuous stay abroad for 12 months. For Bienes Personales the CUIT of the substitute taxpayer (responsable sustituto) is given, who must accept the appointment.
art. 102, 104 LIG t.o. 2019 (beneficiaries abroad) — Payments to beneficiaries abroad are subject to a final 35% tax on net income, which the law presumes as a percentage of the payment: 70% — pay of people working in Argentina temporarily (art. 104 inc. e); 60% — technical assistance and consulting, 80% — patents and licences (inc. a); 35% — copyright (inc. b); 43% — interest on deposits and certain loans, 100% — other loans (inc. c–d); 60% — rent from real property in Argentina (inc. g, with an option for actual expenses); 90% — other income (inc. i). The effective rate is therefore 24.5%, 21%, 28%, 12.25%, 15.05% (35% on other loans), 21% or 31.5% of the payment; dividends — 7% (art. 97).
FBR — Bilateral full scope treaties (list of Pakistan's comprehensive income tax treaties) — Lists 68 treaty partners of Pakistan (page opened 10 Nov 2026); Argentina is not on the list.
Ministerio de Economía de la Nación — «Convenios para evitar la doble imposición vigentes» (page updated 23 Oct 2026) — List of Argentina's treaties to avoid double taxation in force; Pakistan is not on it.
ARCA — «Convenios internacionales: Países» — ARCA's list of countries with which Argentina has international tax agreements; Pakistan does not appear on it.
arts. 165–175 LIG t.o. 2019 (credit for foreign taxes) — Residents credit «similar» taxes actually paid abroad on foreign income (taxes on net income or allowing substantial expenses to be deducted; also final withholding of the source State), up to the Argentine tax on that income; the uncredited part is carried forward to the next 5 years, after which it is lost. No treaty is needed for this.
Income Tax Ordinance, 2001, s. 103 — A resident taxpayer gets a credit for foreign income tax on foreign-source income equal to the lesser of the foreign tax paid and the Pakistan tax on that income (average Pakistani rate × net foreign-source income), computed separately for each head of income; unused credit is not refunded, carried back or forward; the foreign tax must be paid within two years after the end of the tax year.
Income Tax Ordinance, 2001, s. 102 — Foreign-source salary received by a resident individual is exempt if the individual has paid foreign income tax on it; tax is treated as paid if it was withheld by the employer and paid to the revenue authority of the country where the employment was exercised.
Income Tax Ordinance, 2001, s. 82(d) (inserted by the Finance Act, 2022; FBR consolidated text amended up to 30.06.2026) — Resident individual: one who, being a citizen of Pakistan, is not present in any other country for more than one hundred and eighty-two days during the tax year or who is not a resident taxpayer of any other country.
Income Tax Rules, 2002, rule 19B — A non-resident may apply to the Competent Authority of Pakistan for a certificate of tax paid in Pakistan (by deduction, collection or otherwise) for presentation to the tax authority of the country of residence; proof of residence in that country is required.
Income Tax Ordinance, 2001, s. 51 — (1) A citizen who becomes resident in a tax year after being non-resident in the four preceding tax years: foreign-source income is exempt in that tax year and the following one. (2) A citizen who leaves Pakistan during a tax year and remains abroad for the rest of it: salary earned outside Pakistan in that year is exempt.
ARCA — step-by-step guide «Residencia en el exterior: ¿Cómo acredito la pérdida de la residencia?» — Loss of residence takes effect from the 1st day of the month following the event and must be proved by the taxpayer: with a certificate of permanent residence from the foreign authority, or with a passport, consular certificate or other reliable document showing departure and a stay abroad for the required period; documents in a foreign language — with a sworn translation and the text of the apostille.
Ley 23.966, Título VI (Impuesto sobre los Bienes Personales), arts. 17, 24–26, as amended by Ley 27.541 (arts. 30–31) and Ley 27.743 (art. 63) — Residents (since 2019 the «domicile» criterion has been replaced by residence under the LIG) pay tax on assets in Argentina and abroad, non-residents only on assets in Argentina. The tax-free minimum in the law is ARS 100,000,000; the taxpayer's home is exempt up to ARS 350,000,000 (both amounts are indexed to the CPI annually). Rates for 2026: 0.5% and 0.75% of the excess; from 2027 — 0.25%. For non-residents the 0.5% tax is paid by the substitute taxpayer in Argentina; on interests in Argentine companies — by the company itself (0.5%).
Ley 27.743, Título III (REIBP), arts. 45–58 — People who were residents on 31 Dec 2023 and joined the special REIBP regime in 2024 paid Bienes Personales in advance for 2023–2027 (0.45% of five times the base) and are exempt from it up to and including 2027.
arts. 97–99 LIG t.o. 2019; art. 26 inc. n), u) (as amended by Ley 27.802) — Dividends of individuals — 7% (withheld as a final tax; the same rate for beneficiaries abroad). Gains on securities — 5% (non-indexed peso instruments) or 15% (indexed or foreign-currency instruments, shares not meeting the exemption conditions); gains on the sale of listed shares, government bonds, etc. are exempt under art. 26 inc. u). Sales of real estate in Argentina (art. 99, 15%) are exempt from 1 Jan 2026, as is income from letting housing for residential use (art. 26 inc. n) as amended by Ley 27.802).
Decreto 406/2026 (Boletín Oficial 01.06.2026) — Regulation of the exemptions introduced by Ley 27.802: income from letting housing for residential use accrued from 1 Jan 2026 is exempt; gains on the sale of real estate in Argentina (art. 99) are exempt from 1 Jan 2026 for individuals — residents and non-residents.
Income Tax Ordinance, 2001, s. 82(c) — An individual is a resident individual for a tax year if he or she is an employee or official of the Federal Government or a Provincial Government posted abroad in the tax year — regardless of days in Pakistan.
Income Tax Ordinance, 2001, s. 101 — Salary is Pakistan-source to the extent it is received from employment exercised in Pakistan (wherever paid) or is paid by or on behalf of the Federal, a Provincial or a Local Government in Pakistan (wherever the employment is exercised). Dividends of resident companies, profit on debt and royalties paid by residents, rent and gains on immovable property in Pakistan, gains on shares of resident companies and pensions paid by residents are Pakistan-source; everything else is foreign-source.
art. 94 LIG t.o. 2019 (as amended by Ley 27.743); ARCA — art. 94 scale for 2026 — Progressive scale for individuals: 5, 9, 12, 15, 19, 23, 27, 31 and 35%; the brackets are indexed to the CPI twice a year (January and July). 2026 annual scale (ARCA): 5% up to ARS 2,336,953.69, … 35% above ARS 70,984,968.25 of taxable income.

Updated 10/11/2026. The result is for information only and is not tax or legal advice. The FBR, other tax authorities and courts may interpret the rules differently, including because of circumstances not covered here, and the law changes with each Finance Act. Consult a qualified adviser before making decisions.

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