Leaving Argentina for Paraguay is legal and common. Here is how Argentine tax residence ends, what Argentina still taxes, why ARCA treats Paraguay as low-tax and what that means for your companies — and how to set up the Paraguayan side so it holds.
Thousands of Argentines take Paraguayan residence every year, and many move their business with them: lower taxes, no currency controls, a stable guaraní and a border that is easy to cross. Argentina does not charge an exit tax, and Argentine law says plainly how tax residence ends.
The trouble lies in the details. Argentina treats Paraguay as a low-tax jurisdiction, which brings transfer pricing, presumptions on money arriving from Paraguay and controlled-company rules into play. An owner who moves on paper but keeps living, managing and banking in Argentina can end up taxed in both countries. This guide covers how to leave properly, what Argentina does to Paraguayan structures, and how to set up the Paraguayan side.
Permanent residence abroad
Argentine tax residence ends when you obtain permanent residence in another country under its migration law.
Or 12 months abroad
Without permanent residence elsewhere, after 12 continuous months outside Argentina; visits of up to 90 days in total per 12 months do not break the period.
Effective date
From the first day of the following month.
Paperwork
Proof is filed with ARCA — foreign residence certificate or passport and consular records — with the request to cancel income tax registration.
A 2025 appeal ruling involving a taxpayer who moved to Paraguay held that residence ends by law, not by notice: the court accepted a retroactive cancellation back to the date of the Paraguayan permanent residence. ARCA has appealed to the Supreme Court. File the notice on time anyway — until ARCA processes it, all obligations continue.
Law and practice: Income Tax Law (t.o. 2019), arts. 116–119; Decree 862/2019; RG (AFIP) 4236/2018 and RG 2322; Federal Administrative Appeals Court, Chamber III, “Yege”, 8 April 2025 (not final).
Argentine-source income
Taxed by final withholding, for example 7% on dividends from an Argentine company.
Wealth tax
Argentine assets of non-residents are taxed through a local substitute taxpayer, who must be appointed before de-registration.
Selling Argentine shares
15% on the gain, or 13.5% of the price; indirect sales through foreign holdings can be caught too.
No exit tax
Leaving does not trigger a deemed sale of your assets.
If there is no tax treaty and both countries claim you, Argentina applies its own tie-breaker: permanent home, then centre of vital interests, then habitual abode, then nationality. Your family, home and business management decide it more than any certificate.
| Argentine rule | Effect on dealings with Paraguay |
|---|---|
| Low-tax jurisdiction (corporate tax below 15%) | Yes: Paraguay’s IRE is 10% |
| Non-cooperative list | No: Paraguay was removed in January 2023 |
| Transfer pricing | Applies to every transaction with a Paraguayan party, related or not |
| Funds arriving from Paraguay | Can be presumed an unjustified increase in wealth unless their origin is proved; Law 27,826 now requires other evidence too |
| Commodity exports via a Paraguayan trader | Export contracts must be registered with ARCA |
| Argentine owner of a Paraguayan company | Controlled-foreign-company rules can tax its passive income in Argentina |
| Payments from Argentina to Paraguay | Full domestic withholding: no tax treaty |
The practical consequence: an Argentine company that buys from, sells to or pays a Paraguayan company — even one you do not own — must price those transactions at arm’s length and, above the thresholds, document them in a transfer pricing study. Since late 2025 the thresholds are ARS 150 million in total or ARS 15 million per transaction.
Law and practice: LIG art. 20 (low-tax test), art. 17 (transfer pricing); Decree 48/2023 (removal from the non-cooperative list); Law 11,683, article after art. 18 (presumption); Decree 767/2025 and RG 5798/2025 (transfer pricing thresholds).
Cleanest for services and remote businesses: the Paraguayan company serves clients directly.
For businesses tied to Argentina: transactions between them follow transfer pricing, and dividends leave Argentina at 7%.
Contributing the shares is a taxable disposal for an Argentine resident; do it after residence has changed and get the valuation right.
Possible, but registered with ARCA and priced at market; expect scrutiny.
Whatever the structure, the Paraguayan company needs substance: real management, people and decisions in Paraguay. A Paraguayan company run from Buenos Aires is an Argentine company for tax purposes in all but name.
| Step | Where | Why it matters |
|---|---|---|
| Obtain Paraguayan residence | Migration authority (DNM) | Permanent residence abroad ends Argentine tax residence |
| Keep proof of the move | Paraguayan ID, residence resolution, migration record | ARCA and the courts look at documents and dates |
| Notify ARCA and cancel income tax registration | ARCA, with sworn translation where needed | Until then, filing obligations continue |
| Appoint a substitute for wealth tax | An Argentine resident who accepts the role | Required before de-registration is processed |
| Live the move | Paraguay | Centre of life and days spent are the tie-breaker |
| Get a Paraguayan tax residence certificate | DNIT, yearly | Evidence for banks, Argentina and third countries |
For individuals, Paraguay generally treats more than 120 days in the country in a year as tax residence, and taxes personal income territorially at 8–10%. Since July 2026, converting temporary to permanent residence requires documented economic solvency, such as active income, and no absence of more than a year. An investment of US$70,000 in a business with five jobs, under the Investor Pass, gives permanent residence directly.
Law and practice: Paraguay: Law 6984/2022 (migration); DNM Resolution 407/2026; MIC Resolution 283/2026 (Investor Pass); RG SET 65/2020 (tax residence certificate, issued by DNIT within 10 business days, valid one year).
By obtaining permanent residence in another country, or after 12 continuous months abroad, and filing proof with ARCA to cancel your income tax registration. The change takes effect from the following month.
No. Leaving Argentina does not trigger a deemed sale of assets, although Argentine-source income and Argentine assets remain taxable.
Argentina treats Paraguay as a low-tax jurisdiction because its corporate tax is below 15%, but Paraguay is not on the non-cooperative list since January 2023.
Transfer pricing rules apply to all of them, related or not, and above the thresholds a transfer pricing study is required.
No. Payments from Argentina to Paraguay bear full domestic withholding.
Generally more than 120 days in a year. A tax residence certificate from the DNIT is issued for one year.
Yes, on assets located in Argentina, through a local substitute taxpayer.
Temporary, permanent and citizenship, step by step.
Dividends, BOPREAL and the 90-day rule.
Tell us what you own in Argentina and how you want to work from Paraguay. We plan both sides and handle the Paraguayan residence and company — fixed quote within one business day.
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