Estonian Company Run from Argentina: Tax Rules

Some entrepreneurs who live in Argentina form or buy an Estonian private limited company (OÜ), often as e-residents, and run it from Buenos Aires or Córdoba. That works, but Argentine income tax does not stop at the border: a place of management or administration in Argentina is a permanent establishment of the foreign company, and Argentine residents who control a foreign company can be taxed on part of its retained profit. Estonia and Argentina have no tax treaty. This guide sets out these rules with the official text, and what we do on the Estonian side.

The guide is general information, not tax advice. How your company and you are taxed depends on the facts of your case; ask an Argentine tax adviser before you form or buy the company. We read the Income Tax Law (Ley de Impuesto a las Ganancias), ordered text approved by Decree 824/2019, in the updated text of InfoLEG, the official legal database of the Argentine Ministry of Justice, with amendments up to Law 27.802 (Official Gazette of 6 March 2026), and the Estonian Ministry of Finance's list of tax treaties, on 24 October 2026.

In Estonia: an Estonian company is Estonian

A company established under Estonian law is resident in Estonia for tax purposes (Income Tax Act § 6). Its profit is taxed when it is distributed, not while it stays in the company — the guide how Estonia taxes company profit explains the rule. The company keeps its Estonian duties wherever its owners live: accounts, an annual report to the commercial register and, if its address is abroad, a contact person in Estonia.

In Argentina: the company side

Resident companies are those formed in Argentina. Residents are taxed on all their income from Argentina and abroad; non-residents only on income from Argentine sources (Income Tax Law, article 1). Resident companies are the companies constituted in Argentina (article 116(d) with article 73(a)), which an Estonian OÜ is not.
A place of management is a permanent establishment. A permanent establishment is a fixed place of business through which a foreign person carries on all or part of its activity, and the term includes in particular a place of management or administration (article 22).
Rate. Companies constituted in Argentina pay income tax on a progressive scale of 25, 30 and 35 per cent, with bands adjusted every year for inflation (article 73(a)). A permanent establishment pays on the same scale and an additional 7 per cent when it remits its profit to its head office (article 73(b)).

An Estonian OÜ is not an Argentine resident company. If you live in Argentina and manage the business from there, Argentina can treat that place of management as a permanent establishment of the Estonian company and tax the profit attributable to it. Your Argentine tax adviser answers that with the facts of your case.

In Argentina: the owner side

Who is a resident individual. Argentine nationals are resident, and so are foreign nationals who have obtained permanent residence or who have stayed in Argentina with temporary permits for 12 months (article 116(a) and (b)).
Controlled foreign company rule. Argentine residents — companies and individuals — are taxed on their share of the income of a foreign company when all the conditions are met: alone or with related persons they hold 50 per cent or more of its equity, results or votes, or otherwise control it; the foreign company lacks the staff and means to carry on its activity, or its income is passive income of at least 50 per cent of its income, or income that gives related Argentine residents deductible expenses; and the tax it actually pays on that income is lower than 75 per cent of the Argentine corporate tax (article 130(f)). Only the income of the kind the rule names is attributed.

An Estonian company pays no income tax on profit it retains. If its owner lives in Argentina and its income is passive, the rule can attribute that income to the owner. Your Argentine tax adviser answers that with the facts of your case.

No tax treaty between Estonia and Argentina

No treaty. Argentina is not on the Estonian Ministry of Finance's list of tax treaties in force, signed or initialled.
What that means. There is no treaty rule on a permanent establishment or on the tax on dividends and board fees — each country applies its own law. See board member fee or dividend from abroad for the Estonian side.

What to decide before you form or buy the company

Where the business is managed. A place of management in Argentina is a permanent establishment.
What the company earns. Passive income of a company controlled from Argentina can be attributed to its owners there.
How profits reach you. Without a treaty, each country applies its own rules to dividends and board fees.

The two company forms side by side — founding document, capital, share transfer and the company tax: Estonian OÜ or Argentine S.R.L..

What we do on the Estonian side

for your own company, a written analysis of its tax residence and permanent establishment under these rules — an analysis, not tax advice;
online formation for an e-resident — €950 Registered address and contact person service for one year are included., or formation by power of attorney — €1,250;
a ready-made company bought remotely — €1,200 Registered address and contact person service for one year are included.;
accounting — from €150 / month and the annual report — from €450;
the registered address and contact person after the first 12 months — €350 / year.

Our accounting covers the Estonian company's Estonian obligations. Argentine tax returns and Argentine tax advice are not included. Owners in other countries: Estonian company run from abroad compares the rules side by side.

Prices exclude VAT. All communication takes place by email.

Ready to start? A new Estonian company — online for e-residents or by power of attorney; Argentine tax advice is not included. Order.

Official sources

The laws this article names, by the name of their official text, as read on 9 October 2026. For the Estonian acts we read the English translation in Riigi Teataja; the legally binding text is the Estonian one.

Income Tax Act — Riigi Teataja, English translation

Sources are named in the text, without links. To see which of our services your company needs, open the Business Navigator.

Frequently asked questions

Is my Estonian company taxed in Argentina if I run it from Argentina?

It can be. A company is resident in Argentina only if it was constituted there, but a place of management or administration in Argentina is a permanent establishment of a foreign company (Income Tax Law, article 22), taxed on the scale of 25, 30 and 35 per cent plus 7 per cent when profit is remitted (article 73). Argentine residents who control a foreign company with mainly passive income and low tax can be taxed on their share of that income (article 130(f)). In Estonia the company stays resident because it was established under Estonian law (Income Tax Act § 6). Estonia and Argentina have no tax treaty, so each country applies its own law. Ask an Argentine tax adviser before you form or buy the company; we handle the Estonian side.

Estonian company run from Argentina: what is taxed where