The government of Santiago Peña, through the National Directorate of Tax Revenue (DNIT), is advancing new rules on retained corporate profits but denies that it constitutes a new tax. In an interview, DNIT Director Óscar Orué clarified that General Resolution No. 49/2026 is informational and control-oriented, without changing rates or mandating dividend distribution.
“DNIT does not seek to regulate retained earnings, but to improve transparency and information availability,” Orué said. The measure requires certain companies to detail in explanatory notes to their financial statements the origin, composition, and destination of reserves and accumulated profits. According to him, the decision responds to the “strong growth” of these items in recent years and the need for better economic and tax analysis tools.
Orué explained that the bill on the matter is still under technical analysis, shared with the Ministry of Economy and Finance (MEF). “The focus is to evaluate possible adjustments to the Dividend and Profit Tax (IDU) regime, considering balance sheet information, the stock of retained earnings, and their fiscal impacts,” he said. Only after this stage will it be decided whether a legal reform is necessary.
The private sector has expressed concern about a possible indirect increase in the tax burden. Orué countered: “RG 49 does not create a new tax, does not modify rates, and does not require profit distribution.” He stressed that the resolution is merely informational and control-oriented, aimed at improving oversight capacity through data cross-referencing and technological tools.
The director also denied any intention to limit the use of corporate reserves. “Current regulations do not establish limits on the use of reserves nor provide for the application of taxes on them at the time of their creation or maintenance,” he emphasized. He noted that the taxable event for IDU remains exclusively the actual distribution of profits.
Amid uncertainty, some companies have begun capitalizing or distributing profits early. Orué considered that these moves could have positive effects on the economy. “Capitalization of reserves contributes to strengthening corporate equity, generating productive assets, expanding economic activity, creating jobs, and improving profitability prospects for shareholders,” he said, describing the process as a “virtuous circle.”
Asked about possible constitutional conflicts related to private property and business autonomy, Orué responded that since there is no concrete regulatory proposal yet, it is not appropriate to claim constitutional conflicts exist. “DNIT’s priority is to advance in spaces of technical dialogue with the sectors involved and to build any eventual measure on evidence and technical criteria,” he concluded.