Unfortunately, the difficulty that arises now for many holding or seeking termporary and permanent residency is less associated with the horrors of the DMN system but instead one associated with the Bienes Personales tax. As I have commented on a separate thread (https://baexpats.org/threads/rentista-visa-from-rents-collected-in-2019.41874/page-4#post-378333), it seems clear that the Bienes Personales tax has always applied to any and all temporary and permanent residents and citizens who, in addition to any assets they may hold in Argentina, have assets in their home country or elsewhere in excess of the low minimum threshold value. It also seems clear that the changes recently introduced by the new government (i) greatly increase the tax, to as much as 2.25% of the value of those assets on 31 December each year, and (ii) close the loophole that up until now has allowed Argentinians and expats aware of the tax and interested in avoiding it to slip through: that is by declaring their domicile to be an address overseas. From now on, the tax will apply to any Argentine and permanent/temporary resident/citizen who spends more than 90 days in the country each calendar year, regardless of where they declare themselves to be “domiciled”. The only exception in the case of expatriates with overseas assets was (and it appears will continue to be) those whose temporary or permanent residency exists by virtue of an employment contract of less than five years duration. The only other escape hatch would be where our home country levies on us an equivalent wealth tax and there is a double taxation treaty that saves us from paying it a second time here. But as these wealth taxes are rare, it is unlikely that most of us pay such a tax at home and even less likely that a double taxation treaty protects us from paying it a second time here. The exception would seem to be France, which does appear to have a wealth tax and which does also appear to have a double taxation agreement with Argentina that specifically mentions Bienes Personales as a tax that may not apply if the individual has already paid its French equivalent.
For the rest of us here who have assets overseas, it seems we are liable to either pay AFIP 2.25% of their value each year, or consciously evade the tax and hope we never get caught (at 2.25%, in the event of a crackdown back taxes will cumulate in just a few short years to quite a large sum, depending on the value of the overseas assets). So, for almost all current and prospective temporary and permanent residents and citizens with assets outside Argentina (i.e., anyone who is not French or who is not using an employment contract of less than five years duration as the basis for their residency), the situation has suddenly become quite complicated and/or expensive and possibly no longer even viable. The most exposed would seem to be those seeking or already using the Rentista category, since it would be very risky to hide overseas assets from one part of government (AFIP) having previously declared them to another (DMA).
If anyone has information that contradicts any of the above and the contents of my posts in the other thread (none of which I have obtained from a tax professional here; it is merely the result of my own research since the changes to the Bienes Personales tax became public in December), that would of course be greatly appreciated. I would be delighted to discover I am mistaken. One of the posts also contains a link to Argentina's double tax treaties; most of them seem to state in the first couple of clauses the taxes that are covered in both countries, and from that it is possible to deduce whether relief from the Bienes Personales tax in Argentina is included because the other country levies a similar tax on its tax payers. I specifically looked that French one, because I read that France is one of the few country to also apply a wealth tax, so it seemed like an interesting case study, and indeed proved to be. There may be relief for tax payers in other countries, but it seems unlikely; still, it is worth checking.
For the rest of us here who have assets overseas, it seems we are liable to either pay AFIP 2.25% of their value each year, or consciously evade the tax and hope we never get caught (at 2.25%, in the event of a crackdown back taxes will cumulate in just a few short years to quite a large sum, depending on the value of the overseas assets). So, for almost all current and prospective temporary and permanent residents and citizens with assets outside Argentina (i.e., anyone who is not French or who is not using an employment contract of less than five years duration as the basis for their residency), the situation has suddenly become quite complicated and/or expensive and possibly no longer even viable. The most exposed would seem to be those seeking or already using the Rentista category, since it would be very risky to hide overseas assets from one part of government (AFIP) having previously declared them to another (DMA).
If anyone has information that contradicts any of the above and the contents of my posts in the other thread (none of which I have obtained from a tax professional here; it is merely the result of my own research since the changes to the Bienes Personales tax became public in December), that would of course be greatly appreciated. I would be delighted to discover I am mistaken. One of the posts also contains a link to Argentina's double tax treaties; most of them seem to state in the first couple of clauses the taxes that are covered in both countries, and from that it is possible to deduce whether relief from the Bienes Personales tax in Argentina is included because the other country levies a similar tax on its tax payers. I specifically looked that French one, because I read that France is one of the few country to also apply a wealth tax, so it seemed like an interesting case study, and indeed proved to be. There may be relief for tax payers in other countries, but it seems unlikely; still, it is worth checking.
