Keep your Argentine entity's domicilio fiscal Confirmed with ARCA and its sede social current at IGJ, so a routine move never triggers an ex officio address or a contribuyente no confiable flag.
Domicilio Fiscal Change Reporting Deadline
10 business days (ARCA)
Tax ID
CUIT
Primary Registry
ARCA
An Argentine entity's sede social, filed with IGJ as part of its bylaws, is legally distinct from its domicilio fiscal, the place of actual, effective administration filed with ARCA, formerly AFIP, and the two are maintained independently, updating one never automatically updates the other. A virtual office or coworking address is accepted only with heightened IGJ scrutiny, typically requiring a notarial certification act, an escribano público attesting the address's real physical existence, particularly for SAS entities. Under RG 5809/2026, effective March 2, 2026, ARCA classifies every domicilio fiscal as Confirmed, Observed, or Non-existent, with an Observed status giving a 30-calendar-day cure window before the address risks being constituted ex officio, without a prior hearing, following two failed mailed confirmation attempts. A domicilio fiscal that can't be proven risks a contribuyente no confiable flag and a CUIT limitada, restricting the ability to issue invoices normally. Any domicilio fiscal change must be reported to ARCA within 10 business days, while a sede social change requires a directors' resolution, a notarial or private instrument, and an IGJ filing reported within 5 days of the change, with fees running 12 to 144 módulos depending on whether the bylaws include the address and whether expedited processing is used.
Sede social filed with IGJ as part of the bylaws, legally distinct from the domicilio fiscal filed with ARCA, the place of actual, effective administration, maintained independently with no automatic sync between the two
Virtual office or coworking address accepted only with heightened IGJ scrutiny, typically requiring a notarial certification act attesting the address's real physical existence, particularly for SAS entities
Domicilio fiscal classified as Confirmed, Observed, or Non-existent under RG 5809/2026, with an Observed status giving a 30-calendar-day cure window before ARCA can constitute an address ex officio
Contribuyente no confiable flag and CUIT limitada risk when the declared domicilio fiscal can't be proven, restricting the ability to issue invoices normally
Domicilio fiscal change reported to ARCA within 10 business days, while a sede social change requires a directors' resolution and IGJ filing reported within 5 days, with fees of 12 to 144 módulos depending on the bylaws and processing speed
If two mailed confirmation attempts to the declared domicilio fiscal both fail, ARCA can constitute a different address ex officio, without a prior hearing, and that imposed address remains enforceable even while under appeal.
IGJ's sede social and ARCA's domicilio fiscal are filed with different agencies under different rules. A company in good standing with one can simultaneously be Observed, or worse, with the other.
Legal and accounting guides written before March 2026 still reference AFIP and the superseded RG 2109 regime. Advice citing those without updating for ARCA and RG 5809/2026 no longer reflects the current process.
Preparation of the notarial certification act needed to support a virtual office or coworking address as a valid sede social, particularly for SAS entities
Monitoring of ARCA's Confirmed, Observed, or Non-existent domicilio fiscal status, curing an Observed flag within its 30-calendar-day window
Domicilio fiscal change reporting to ARCA within the 10-business-day window, avoiding contribuyente no confiable exposure
Coordination of the directors' resolution, notarial instrument, and IGJ filing for a sede social change, reported within the 5-day deadline
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