General Resolution 5804/2025 was released by the Argentine Ministry of Justice in the Official Gazette at the end of 2025. The document appeared narrow and technical at first. In actuality, it modifies the collection and transmission of financial data linked to digital platforms to the tax authority. The act grants the ARCA more power to modify the reporting framework that was initially established under General Resolution 4614, which addressed the transfers of both traditional and virtual assets.
The changes do not create an entirely new system. Instead, they expand the reach and depth of information already being submitted. For payment service providers and similar platforms, the Resolution signals a clear expectation: ARCA intends to see more detail, more participants, and clearer transaction trails. While the updated dataset will only be applied to future filings, the framework itself is already in effect, leaving platforms little room to treat this as a distant issue.
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Who falls within scope
Instead of using formal classifications, the Resolution uses functional criteria. The scope includes any organisation that oversees, controls, manages, or processes asset movements via digital or electronic platforms. PSPs that provide payment accounts fall under this category, even if those accounts are formally maintained by other organisations.
Activity, not custody, determines responsibility. Platforms that identify as merely technical interfaces or intermediaries are not immune. They have reporting responsibilities if they facilitate asset flows or account use.
Both assets managed for individuals and legal entities are subject to the same regulations. The residence of the user is unimportant. For reporting purposes, Argentine and non-Argentine users are treated equally, placing foreign PSPs that cater to Argentine clients squarely within ARCA’s purview.
Account information to be submitted
The resolution supports the implementation of periodic submission of a full inventory of client accounts, covering account openings and closures and changes in the accounts, along with monthly inflows, outflows, and closing balances. What seems most important is the expansion of personal and structural data linked to these accounts.
It is now required to not only have the main account holder but also have other participants connected with the account in the platforms. The function, nationality, identification details, tax number, and relevant dates of each participant need to be indicated. Further, the total count of linked accounts per participant should be given.
This approach shifts the focus away from simple balance reporting. ARCA is clearly interested in understanding who is behind the accounts and how access or control is distributed. For PSPs, this often means reconciling onboarding data with transactional systems that were not originally designed to communicate at this level.
Transaction detail and identification of counterparties
Transaction reporting is also expanded. Each reported movement must indicate the currency used and its equivalent value in Argentine pesos. This applies to local currency, foreign currency, and digital assets alike.
For activities that surpass certain volume thresholds, the platform will be required to disclose points of origin or points of reception. This practice will infuse counterparty transparency within the reporting framework, which has been more oriented up to now on aggregated data. This may not be infrequent for high-volume platforms. The source and receiving accounts’ identification is going to have to become part of routine reporting, which will indeed ramp up the data volume and enhance internal consistency.
Practical implications for PSPs
- The main pressure point for PSPs is operational, not legal. Many platforms have the layer of systems that have been put together over a period of time and across jurisdictions. Resolution points toward closer integration between client identification, account management, and transaction tracking.
- Another sensitive area is legacy clients, more so non-residents. The information collected over the years might no longer be relevant to the current expectations. Bringing the older accounts into line may need more client interaction and internal review.
- While the updated dataset applies only to future filings, preparation cannot be left to the last moment. Platforms that underestimate the internal coordination required are likely to face friction once reporting begins under the new format.
Our assistance
Given the technical and cross-border nature of the changes, many PSPs seek external guidance when adjusting their reporting practices.
Eli Deal works with financial platforms and payment providers on issues related to tax data disclosure and cross-jurisdictional compliance. In the context of the new ARCA framework, such support often focuses on interpreting reporting expectations, aligning internal data flows, and reducing the risk of inconsistent submissions.
Conclusion
General Resolution 5804/2025 gives more detail to a clearly increasing trend across tax administrations in Argentina: in the eyes of the state, digital platforms and PSPs have shifted from peripheral to core data suppliers. The posture taken with the level of detail that is now to be supplied makes it clear that policy choice has been made in favor of transparency over simplicity. The relevant question for the platforms affected was not whether further data would need to be provided but rather just how efficiently systems could be adapted to deliver it. Those who consider these changes a structural update will adjust their operations much better than those who just view it as a formal adjustment when the enriched reporting becomes standard.
FAQ
What are the tax rules in Argentina?
The country follows a widespread tax system regarding income, consumption, and assets. Both individuals and companies working within the territory in question are subject to national taxes, including income tax, VAT, and provincial and municipal levies. The system is very document-intensive and relies quite heavily on information reported by banks, payment platforms, and other financial intermediaries. Recently, the tax authority has departed from self-declaration and has been using third-party data to verify the position of taxpayers.
What are the tax residency rules in Argentina?
For an individual, this concept is generally based on physical presence and personal ties with the country; that is, an individual is considered a resident of the country in which he stays longer or establishes a habitual center of life. Legal entities are considered residents if they are constituted under its laws or have their effective management within the country. Residency matters because it determines the scope of income that falls under the tax system.
Does Argentina tax foreign sourced income?
Yes. Tax residents of Argentina are taxed on their worldwide income, not only on income generated locally. This includes income earned abroad, whether from employment, business activities, investments, or digital assets. Non-residents, by contrast, are taxed only on income with an Argentine source. This distinction is central to how the tax authority evaluates information received from foreign banks, PSPs, and digital platforms.
