August 19, 2022
Argentine Tax Authority establishes one-time windfall corporate income tax prepayment
On 16 August 2022, the Argentine Tax Authority (AFIP) published General Resolution No. 5248/2022 (the Resolution) establishing a one-time “windfall income tax prepayment” for companies that have obtained extraordinary income derived from the general increase in international prices.
General Resolution No. 5248
The Resolution establishes that the “windfall income tax prepayment” would apply to companies that meet one of the following requirements:
For purposes of determining whether the above thresholds are met, the Resolution clarifies which tax years taxpayers must take into account:
The amount of the “windfall income tax prepayment” is determined in accordance with the following:
The “windfall income tax prepayment” will be creditable against the corporate income tax liability determined in the following tax years:
The “windfall income tax prepayment” is paid in three equal and consecutive monthly installments and the due dates will depend on the month of the year-end, starting on 22 October 2022.
The Resolution excludes from the “windfall income tax prepayment” those entities that obtained an income tax exemption certificate valid for tax year 2021 and tax year 2022.
Taxpayers should carefully assess the new rules by taking into account their facts and circumstances, especially in light of the extraordinary character of the “windfall income tax prepayment.”
For additional information with respect to this Alert, please contact the following:
Pistrelli, Henry Martin & Asociados S.R.L., Buenos Aires
Ernst & Young LLP (United States), Latin American Business Center, New York
Ernst & Young LLP (United Kingdom), Latin American Business Center, London
Ernst & Young Tax Co., Latin American Business Center, Japan & Asia Pacific