Exceptions to the new regime: which digital wallet payments will not be subject to Gross Income Tax in PBA

The province of Buenos Aires took a new step in tax modernization by confirming that, starting October 1st, digital wallets operating in the district will begin applying automatic withholdings on amounts credited to users' payment accounts . This represents the formal incorporation into the Computerized System for Collection and Control of Credits in Payment Accounts (SIRCUPA) , a tool already operating in almost all jurisdictions in the country and which seeks to align the system with the one currently in place in banks through SIRCREB.

With this measure, the Buenos Aires government aims to close avenues for tax evasion and guarantee equal treatment between those who use bank accounts and those who receive payments through digital wallets. However, the regulation also clarifies that not all transactions will be covered, as a list of transactions will be expressly excluded from withholdings.

Each time money is credited to a virtual account (CVU), the wallet must consult the registry of the Multilateral Convention Arbitration Commission (COMARB), which assigns the corresponding rate based on the taxpayer's activity. These percentages can vary from 0.01% to 5% , and the amount withheld will be charged as an advance payment against Gross Income .

For taxpayers in the province of Buenos Aires, the general rate is set at 1% , although there are different scales: 0.10% for construction, 0.50% for transportation, 0.80% for liberal professions, and 0.30% for primary and industrial activities . Meanwhile, financial and insurance entities will be directly exempt.

The resolution also details an extensive list of exempt transactions , in order to protect employment, pension, and social security income. Salaries, pensions, bank loans, family allowances, scholarships, subsidies, social programs, and the Universal Child Allowance will not be withheld.

Transactions related to the export of goods, interest on fixed-term deposits, redemptions of mutual funds, government securities, VAT refunds, social security reimbursements, insurance payments, and compensation for labor or expropriations will also not be covered.

Furthermore, transfers from abroad , transactions between accounts held by the same account holder, and refunds issued by tax agencies are expressly excluded. Also excluded are transactions resulting from the "regret button" on purchases of goods and services, which avoids double harm to the consumer.

Axel Kicillof's administration defended the initiative as a tool to strengthen tax collection without creating new taxes , especially in a context of severe pressure on public finances. However, the measure also seeks to close the loopholes for tax evasion that proliferated during the Kirchner administration , when digital wallets expanded without controls equivalent to those of banks.

Experts consulted indicate that the impact will be significant for self-employed individuals, businesses, and SMEs, as they mostly operate with wallets, although they emphasize that the existence of detailed exclusions provides predictability. Meanwhile, the provincial government insists that this is a computable advance payment , not an additional tax. Therefore, taxpayers will be able to deduct it later on their tax returns.