Executive summary

On 2 February 2026, the Argentine National Institute of Industrial Property (INPI) enacted Resolution No. 38/2026 (the Resolution) through publication in the Official Gazette. The Resolution repeals Resolution No. 328/2005 and approves a new regulation governing the registration of technology transfer agreements, in accordance with Law No. 22,426, which applies to all registration applications that are pending at the time the Resolution enters into force. The new framework confirms that the registration of these technology transfer agreements is voluntary and for informational purposes only.

Though the new regulation introduces greater flexibility, clarity and transparency in the INPI registration process, it is important to note that registration remains relevant from a tax perspective, as registration remains a prerequisite to applying for reduced Income Tax withholding rates and to accessing benefits under Double Tax Treaties, if applicable.

Accordingly, the simplification of the INPI procedure does not eliminate the need to assess the tax implications of payments derived from technology transfer agreements.

Also, Disposition No. 63/2026, enacted on 11 February 2026, provides a new simplified form for use when requesting the registration of transfer of technology agreements with Argentine INPI.

Implications

Multinational companies should analyze the tax consequences associated with any new technology transfer arrangements in light of the regulatory framework, particularly in relation to reduced withholding tax rates and access to Double Tax Treaty benefits.