Taxation of a foreign company employee in Argentina

Partigiano

Registered
Hello people!

I was trying to research the topic of corporate tax residency rules in Argentina in case I come to live h.

I have a private limited company registered in EU which I can manage completely remotely from Argentina (everything online).

The company is registered according to the legislatation of that particular EU country and has a legal address there. Its bank account is in EU + transferwise. No bank accounts will be opened in Argentina.

I will work completely remotely over internet and provide only services (no physical goods) over internet from home, library or wherever. There will be no permanent offices opened in Argentina.

Under which conditions can Argentina claim that my company is a resident of Argentina or has a permanent establishment in Argentina? Does working remotely online from home office qualify as “permanent establishment”? I’m talking about a typical freelancers position.

A) if in the beginning I stay on a tourist visa, maybe ask for one prórroga and make a couple of visa runs to Chile, do I need to bother at all with Argentinian taxes (even if I spend over 183 days during a year in total)?

B) if at some point a get a residency in ARG and (I assume) this would make me an Argentinian tax resident (in a personal capacity), can I use the following scheme:

-assign myself a salary from my own company but declare it to Arg as Argentinian tax resident (so that I get social insurance)?
-keep my company still out of Argentinian tax jurisdiction and not need to pay corporate income tax (cause in my country it’s 0% as long as the money is not taken out of the company or used for valid business expenses)

In addition - I would be sole owner and employee, no clients in Argentina, no bank accounts in Argentina - everything done remotely.

Muchas gracias :)
 

sergio

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Consut a lawyer and probably accountant in Argentina who is familiar with such situations involving Europeans working here. Make sure you get someone from a respected law firm and not just any old lawyer who will gladly take your money without having the expertise you need. On this website you will get a lot of opinions but not necessarily facts.
 

Pensador

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Uruguay does not tax expats on foreign earned income only income you make in Uruguay. Makes URU attractive from that stand point. And not to insult anyone URU is better in many ways if you can afford it. It much more like a first world country. I do not have that option at the moment as my wifes mother is elderly and her father passed some time ago. So we have to be here we all know how that goes.
 

Fiscal

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How would Argentina tax authorities even know you were physically present in Argentina longer than 183 days?
 

Bajo_cero2

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How would Argentina tax authorities even know you were physically present in Argentina longer than 183 days?
This issues explotes in your face when there is a crisscross of information like when you buy a house for example.
 

Bajo_cero2

Registered
Uruguay does not tax expats on foreign earned income only income you make in Uruguay. Makes URU attractive from that stand point. And not to insult anyone URU is better in many ways if you can afford it. It much more like a first world country. I do not have that option at the moment as my wifes mother is elderly and her father passed some time ago. So we have to be here we all know how that goes.
In Argentina income tax law makes you a tax payer on your worldwide income if you live 6 months and 1 day in Argentina.

In uruguay is almost the same. You have to pay 1% more.


However, seems that in Uruguay (12%) you have to pay vat while in Argentina (21%) you don’t.
 
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Bajo_cero2

Registered
I'll never buy a house in Argentina. And even if I did can't I but it through my wife or in laws?
Marriage means common assets.
In laws are Ok because in Argentina is legal to make apparent legal business. It means that you have a document that says that A is owner of the house while A signs a private and secret document at the notary saying that the real owner is you.
 

Fiscal

Registered
Ok but, if I don't buy a house, will any tax authorities ever realize I'm here past 183 days? I mean, I suppose at the airport customs might bother looking at my passport and count up the days, but are they going to then report me to the tax authorities or just tell me to get on the next plane out of Argentina?
 
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