Citizenship, Residence and Tax Residence: Three Different Things

Citizenship is the legal bond of nationality between a person and the Argentine State. Under the investment pathway introduced into Law 346 by Decree 366/2025, it is granted without a prior residence requirement. It entitles the holder to an Argentine DNI and passport, and to the civil and political rights of Argentine citizens.

Argentina does not require new citizens to renounce their prior nationality, and Argentine citizenship is not subject to an obligation to live in the country.

Residence is an immigration status granted to foreign nationals under Migration Law 25,871 — temporary or permanent. It is a different procedure, with its own requirements and, as a rule, an expectation of actually living in Argentina.

A person who obtains citizenship through the investment pathway does not need a residence permit: as an Argentine citizen, they may enter, live and work in Argentina freely. Conversely, holding residence does not lead to citizenship under the investment pathway; the ordinary naturalisation route by residence is a separate regime.

Tax residence determines whether a person is taxed in Argentina on worldwide income. Under Argentine income tax rules, it is generally linked to facts — permanent residence, length of physical presence in the country and the centre of personal and economic interests — rather than to nationality alone.

Consequently, a new Argentine citizen who continues to live abroad does not become an Argentine tax resident merely because of their passport. However, the rules of their current country, the facts of their life and any applicable double-tax treaty must be analysed case by case.

Some countries — most notably the United States — tax on the basis of citizenship. For their own citizens, acquiring a second nationality does not change the home-country tax position.

• "An Argentine passport makes me an Argentine taxpayer." Not by itself; tax residence depends on facts.
• "Citizenship by investment is a residence program." No. Argentina grants nationality directly; residence-by-investment programs such as European golden visas are a different category.
• "I must live in Argentina to keep my citizenship." No residence obligation applies to citizens.
• "A second passport changes my home-country tax." Only if the home country's rules so provide; for most, tax follows residence, not nationality.

Investors who intend to relocate to Argentina should obtain Argentine tax advice before arrival, as becoming a tax resident has consequences for worldwide income and assets. Investors who will remain abroad should confirm the position in their country of residence and in any country where they hold assets.

Professional coordination between Argentine counsel and the investor's home-country tax advisers is the appropriate way to address these questions. Discuss an Argentina CBI case.