Overview
- The Agencia de Recaudación y Control Aduanero published Resolución General 5855/2026 on Wednesday, replacing decades‑old rules and creating a new process for beneficiaries abroad to claim benefits under Argentina’s double taxation treaties.
- Under the resolution beneficiaries must present a certificate of fiscal residence that is apostilled or consularly legalized unless the issuing country provides an official electronic verification system.
- If a certificate lacks an explicit validity period the rule treats it as valid for 12 months from issue, and for recurring payments a single timely certificate covers successive disbursements under the same contract.
- Payers and withholding agents must collect a standardized sworn declaration with specific data, retain contracts and invoices, register or correct certificates in SIRE, and reimburse any excess withholdings when a late certificate is accepted.
- The change affects companies, tax advisers and multinational groups by shifting verification duties onto payers, creating near‑term operational work to update forms and systems, and aiming to reduce prior bureaucratic delays while aligning procedures with international practice.