This source principle was set aside in 1992 when the ITL was amended in order to tax residents in the country over their worldwide income. Nevertheless, at that time the ITL was not amended in order to regulate important concepts regarding the determination of the worldwide income, such as who shall be considered as resident, how the income of a foreign source was supposed to be assessed, etc. The reform covers these issues incorporating a new title to the ITL, this title having ten chapters and more than 60 articles that regulate in a detailed manner the concept of foreign source income. Residents are considered individuals of Argentine nationality, except those who have lost their condition as residents because they have acquired the condition of residents of a foreign country or due to their permanence abroad during a period of 12 months. Also considered as residents are those individuals of foreign nationality who have obtained a permit for their permanent residence in the country or that have stayed in the country with temporary authorizations during a period of 12 months, except the case where their permanence is due to reasons that do not imply an intention of regular permanence.
Companies incorporated in Argentina are also residents of the country.
Branches and permanent establishments of foreign corporations in our country are not considered residents. Also individuals of a foreign nationality whose presence in the country is due to labor reasons that require their permanence in Argentina for a period of not over five years, are not considered as residents of the country. The concept of income of foreign source. Income of foreign source is the one originated from assets located, deposited or used economically abroad or from the performance abroad of any act capable of generating an income. Excepted from the concept are those incomes which the ITL considers specifically as of local source, in spite of their foreign origin, like for example, technical, financial or other type of advice rendered from abroad.