Argentina’s tax and customs authority, the Agencia de Recaudación y Control Aduanero (ARCA), has issued Resolution No. 5824, introducing new formal invoicing obligations for corporate directors, managing partners, fiduciary roles, supervisory bodies, and certain court appointed professionals.1
WHY THIS MATTERS
This measure eliminates long‑standing exceptions and expands ARCA’s visibility into payments that historically were not documented through the invoicing system. As of July 1, 2026, directors, managers, trustees (acting as statutory supervisory officers such as corporate síndicos), and certain court‑appointed professionals will be required to issue electronic receipts—even if they receive only one or two payments per year.
For companies, this creates new administrative requirements when paying board members or fiduciary roles. For individuals, the change primarily introduces new formal duties rather than new tax registrations or status changes. While their underlying tax obligations remain the same, the electronic invoicing requirement increases traceability and is expected to result in automatic income reporting within ARCA’s systems.
More Details
ARCA Resolution No. 5824 strengthens digitalisation and tax control by removing exceptions to the invoicing requirement for certain roles and professional activities. The rule mandates that, as from July 1, 2026, the following individuals are required to issue electronic invoices for their compensation:
- Directors of corporations (S.A.) and managing partners of limited liability companies (S.R.L.).
- Statutory supervisors such as corporate trustees.
- Trustees of trusts and board members of cooperatives, when acting in statutory supervisory roles.
- Attorneys, experts, and court appointed auxiliaries, exclusively for fees collected through judicial channels.
Compensation that previously did not require the issuance of receipts is now required to be formally documented through electronic invoicing, becoming part of ARCA’s fiscal record systems.
Individuals subject to this obligation are expected to enable an electronic point of sale and issue invoices through the fiscal authorities authorised platforms in most cases maintaining VAT Exempt status, even when they receive only one or two payments per year.
Additionally, as all electronic invoices flow directly into ARCA’s databases, the corresponding amounts will automatically integrate into the taxpayer’s Simplified Income Tax Return, expanding the pre‑populated information used by the tax authority. This traceability could also allow fiscal authorities to crosscheck the approval of fees, the self‑withholding of Income Tax by the paying entity, and the amounts reported in the individual’s filings.
KPMG INSIGHTS
The new invoicing requirement calls for early planning. Hence, in light of the changes, companies might wish to consider the following:
- Identify all directors, managing partners, fiduciaries, and other affected individuals who will be required to issue electronic invoices as from July 1, 2026, and update internal workflows accordingly (vendor master data, payment release conditions, retention controls).
- Confirm that each affected individual has enabled their electronic point of sale in advance and that compensation paid through judicial processes, fiduciary structures, or supervisory roles is documented consistently.
KPMG Argentina can assist organisations and affected individuals throughout the transition by assessing the tax implications for each director or fiduciary role, supporting the setup of activity codes and electronic invoicing processes, reviewing autonomous taxpayer classifications, and support compliance with individual obligations. The team can also incorporate these newly invoiced fees into the annual Income Tax filings and help companies refine their internal procedures to help support full alignment with the updated requirements. For more details, please see the Contacts section.
ENDNOTE:
1 (In Spanish) Boletín Oficial de la República Argentina, “Resolución General 5824/2026,” published on February 13, 2026.
Contacts
Disclaimer
The information contained in this newsletter was submitted by the KPMG International member firm in Argentina.
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