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November 2, 2022

Argentine Tax Authority extends suspension of mandatory disclosure regime

  • General Resolution No. 5278/2022 suspends the mandatory disclosure regime for an additional 60 calendar days beginning 31 October 2022.

On 1 November 2022, the Argentine Tax Authority (AFIP) published in the Official Gazette General Resolution No. 5278/2022 (the Resolution) extending the suspension of the mandatory reporting regime implemented by General Resolution No. 4838/2020 (Resolution 4838) for an additional 60 calendar days.


On 20 October 2020, AFIP issued Resolution 4838 establishing a mandatory reporting regime for domestic and international arrangements (“planificaciones fiscales,” in Spanish) implemented since 1 January 2019 or implemented before that date if the effects of the arrangements subsist as of 20 October 2020. Under Resolution 4838, taxpayers that participate in any domestic or international tax planning arrangements or tax advisors that participate (directly or through related parties) in implementing tax planning arrangements must comply with the mandatory reporting regime.

On 1 September 2022, the Argentine Tax Authority (AFIP) published in the Official Gazette General Resolution No. 5254/2022, suspending the mandatory reporting regime implemented by Resolution 4838 for 60 calendar days beginning 1 September 2022.1

General Resolution No. 5278

The Resolution extends the suspension of the mandatory reporting regime for additional 60 calendar days beginning on 31 October 2022.

The Resolution states that AFIP has received opinions and input of the various Professional Councils of Economic Sciences of Argentina to make the regime more effective and efficient. However, it is still in the process of evaluating the comments received and working with other institutions that have not yet been involved in the process.


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



  1. For more information, see EY Global Tax Alerts, Argentina implements mandatory disclosure rules, dated 21 October 2020, Argentina's tax authorities launch the "Régimen IPF" service to ensure compliance with mandatory disclosure regime, dated 7 January 2021 and Argentine Tax Authority suspends mandatory disclosure regime, dated 6 September 2022. 

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