The Incentive Regime for Medium-Sized Investments (RIMI): Benefits, Conditions, and Scope

The Incentive Regime for Medium-Sized Investments (RIMI): Benefits, Conditions, and Scope

By María Soledad González

The enactment of the Labor Modernization Law No. 27,802 (Official Gazette 03/06/2026), among a series of labor and tax reforms, created a tax incentive regime aimed at micro, small, and medium-sized enterprises that wish to carry out productive investments in Argentina: the Incentive Regime for Medium-Sized Investments (RIMI).

This article analyzes the Regime from a technical and practical perspective, with the objective that companies qualifying for the Regime can evaluate not only what the law states, but also what it means in practice, what decisions it requires, and which aspects are still pending regulation.

1. Who can adhere to the Regime?

Article 179 of the Law establishes that entities included in Article 53 of the Income Tax Law—that is, essentially legal entities and certain organizations subject to the tax—that qualify as micro, small, or medium-sized enterprises up to the category of Medium Enterprise Segment 2, under the terms of Law No. 24,467, may benefit from the Regime.

Excluded from the Regime are legal entities that access the benefits provided in Title VII of the “Bases Law” – Incentive Regime for Large Investments (RIGI) – and/or any other incentive regime for the same productive investments.

2. What types of investments must be made and when?

The benefits of the Regime apply to productive investments made by micro, small, or medium-sized enterprises in the country during the first two years counted from the date the Regime enters into force (i.e., from 03/06/2026).

“Productive investments” are understood as those aimed at the acquisition, development, manufacture, or importation of new depreciable movable assets—explicitly excluding automobiles—and the execution of works, provided that both are directly linked to the development of productive activities within Argentine territory (Art. 180). Investments in financial assets, portfolio assets, and inventory are expressly excluded from the Regime.

There is a category of investments that receives especially favorable treatment: irrigation systems and equipment, high energy-efficiency assets, anti-hail netting for the agricultural sector, and livestock assets. For these investments, the Law eliminates the minimum investment requirement. In other words, an agro-industrial company that incorporates a technified irrigation system or livestock, even if it does not reach the general minimum for its category, may still access the Regime for those specific investments.

What remains to be clarified is the scope of the expression “directly linked” to productive activities. The regulation must establish the criteria and documentation that ARCA will require to prove this condition.

Article 185 provides that productive investments are considered made in the fiscal year in which they are put into operation and allocated to the generation of taxable income, in accordance with the Income Tax Law.

3. What are the minimum investment amounts?

Article 181 sets minimum investment amounts in U.S. dollars. For microenterprises the threshold is USD 150,000; for small enterprises, USD 600,000; for medium enterprises segment 1, USD 3,500,000; and for medium enterprises segment 2, USD 9,000,000.

A relevant aspect to consider is that the amount of productive investments is computed over the first two years from the Regime’s entry into force, allowing the investment to be distributed across more than one fiscal year within that period. This provides some flexibility for companies planning phased investments, although it will be necessary to verify how the regulation articulates the accumulation of amounts and the exercise of the depreciation option in each period.

4. What are the benefits of the Regime?

4.1. Accelerated depreciation of investments

Article 182 establishes the first benefit of the Regime: the possibility of depreciating productive investments over substantially shorter periods than usual.

Thus, beneficiaries of the Regime may opt to depreciate their investments under the following accelerated depreciation scheme:

• For investments in depreciable movable assets in general, depreciation may be taken in two equal and consecutive annual installments.
• For investments in works, depreciation may be carried out in at least the number of installments resulting from reducing the estimated useful life to sixty percent.
• For agricultural irrigation equipment, high energy-efficiency assets, anti-hail netting, and livestock assets, depreciation may be taken in a single installment, i.e., deducting the entire cost in the year in which the asset is put into use.

However, there is a condition that requires careful analysis: the exercise of the accelerated depreciation option is comprehensive. Once exercised, it must be applied without exception to all productive investments made under the Regime. This implies that it is not possible to choose which assets are depreciated quickly and which are not.

4.2. Early VAT refund

Article 183 regulates the second benefit of the Regime: the possibility of obtaining a refund of VAT input tax credits generated by productive investments after three monthly tax periods from the moment their computation became applicable. In this regard, the provisions set forth in the first unnumbered article following Article 24 of the VAT Law apply, insofar as they do not conflict with the Regime.

It remains pending regulation how this mechanism will be coordinated with ARCA’s general refund procedures, what documentation must be submitted, whether there will be prior audits, and what the actual timelines for reimbursement will be.

5. What are the conditions for maintaining the benefits and the grounds for termination?

Article 186 establishes that if the assets that gave rise to the benefits cease to be part of the beneficiary’s assets within two fiscal years from the time they were allocated, the Regime will be terminated. The consequences are severe: the beneficiary must repay the refunded VAT credits and any underpaid income tax, plus applicable interest, and may also be subject to a fine of up to twice the benefit obtained.

The Law provides three exceptions to termination. The first is the replacement of the asset with another of equal or greater value than the sale price of the replaced asset, allowing for technological renewal without losing the benefit. The second is destruction due to force majeure. The third, and most relevant in practice, is when one-third of the asset’s useful life has elapsed, under the terms and conditions to be established by regulation. This third case is particularly important for sectors with rapidly obsolete assets, but its concrete scope depends on future regulation.

6. Who is excluded from adhering to the Regime?

Article 184 provides that those with final criminal convictions for corruption, tax evasion, or customs or foreign exchange violations; those declared bankrupt; those with firm, enforceable, and unpaid tax, customs, or social security debts; and legal entities whose directors, partners, or administrators fall into any of these situations are excluded from the Regime.

The exclusion of those accessing RIGI for the same investments has already been mentioned, but it is worth adding that the law authorizes the enforcement authority to expand or modify this exclusion criterion, introducing a certain degree of regulatory uncertainty.

7. What analysis should be carried out when deciding whether or not to adhere to the Regime?

RIMI is a useful tool for companies that are in a position to take advantage of it. However, its usefulness depends on each company’s specific tax situation, profitability projections, the structure of the investment project, and the ability to maintain the assets within its holdings during the required period.

The prior analysis should include, at a minimum, a projection of income tax payable with and without the Regime, in order to quantify the actual savings and effective deferral; an evaluation of accumulated or projected VAT input tax credits and the impact of their early refund on cash flow; and an analysis of the company’s overall situation.

8. Final reflection

RIMI is a tax incentive regime for SMEs that may be relevant. Not because its benefits are conceptually novel—accelerated depreciation and VAT refunds are well-known tools—but because it combines them into a scheme accessible to the universe of medium-sized investments.

For companies that are able to meet its requirements, that have projected profitability sufficient to absorb the deductions, and that can commit to maintaining the assets over the required period, the Regime may represent a real and measurable improvement in the financial equation of their investment projects.