The Regulatory Framework for the Incentive Regime for Medium-Sized Investments (RIMI)

The Regulatory Framework for the Incentive Regime for Medium-Sized Investments (RIMI)

Commentary on Decree 242/2026

By María Soledad González

On April 13, 2026, Decree 242/2026 was published in the Official Gazette, through which the National Executive Branch regulated the Incentive Regime for Medium-Sized Investments (RIMI), created by Title XXIII of Law No. 27,802 on Labor Modernization.

The regulation was a long-awaited piece. As anticipated in our previous article, several aspects of the Regime required regulatory clarification for its effective implementation. The Decree addresses some of these points, although it also delegates key operational matters to a joint resolution of ARCA, the Secretariat of Agriculture, Livestock and Fisheries, and the Secretariat of Energy, which must be issued within thirty calendar days.

Below are the main definitions introduced by the Decree and their practical impact for companies considering joining the Regime.

1. Duration of the Regime

Article 1 of the Decree specifies that productive investments covered by RIMI are those made from the entry into force of Law No. 27,802—that is, from March 6, 2026—until a period of two years counted from the entry into force of the joint resolution to be issued pursuant to Article 11 of the Decree.

This definition has an important practical consequence: the two-year period established by the Law is not counted from the publication of the Law or the Decree, but from the joint resolution that has not yet been issued. Investments made between March 6, 2026 and the date of that resolution are included in the Regime, which is relevant for companies that have already made productive investments since the Law entered into force.

2. Certification of beneficiary status

Article 2 establishes that, to qualify as beneficiaries, entities must hold a valid MiPyME certificate at the beginning of the fiscal year in which the first productive investment is made. The rule refers to Resolution SEyPyME No. 220/2019 and its amendments.

Additionally, a provision is introduced for non-profit entities that cannot obtain the MiPyME certificate: they may access the Regime provided they are registered with ARCA under legal forms determined by the agency and meet the turnover and employment thresholds applicable to SMEs.

3. Definition of productive investments

Article 3 defines “depreciable movable assets” covered by the Regime as new assets—excluding automobiles—that qualify as “Capital Goods (BK)” or “IT and Telecommunications Goods (BIT)” under Annex I of Decree No. 557/23. This objective criterion, based on tariff classification, provides predictability in determining eligible assets.

The Decree also includes investments in irrigation systems, anti-hail nets, and depreciable livestock assets, defined as follows:

  • Agricultural irrigation systems: investments aimed at improving water resource management, optimizing water distribution, and enhancing agricultural productivity through precision technology.
  • Anti-hail nets: high-density polyethylene or similar mesh, resistant to hail impact of at least 20 mm and UV-protected, including supporting structures for crop protection.
  • Depreciable livestock assets: animals for reproductive purposes with superior genetics, registered pedigree or controlled breeds, directly used in productive activities in Argentina. This definition significantly narrows the category and excludes commercial livestock acquisitions.

The Decree also considers high energy efficiency investments as those aimed at:

  • acquiring, installing, or developing depreciable assets that generate, store, or transport electricity from renewable sources, or
  • optimizing, recovering, or reducing energy consumption in production units.

4. Works and their degree of progress

Article 4 defines eligible works as the portion of investments allocated to them within the validity period, provided they are used in the beneficiary’s activity. It includes inseparable movable assets and installation costs.

A notable aspect is the inclusion of ongoing works: projects with less than 30% progress at the time the Law entered into force are eligible. The method to certify this percentage is left to the future joint resolution.

5. Conversion of the minimum investment amount

Article 7 clarifies that the minimum investment amount is calculated net of VAT, discounts, and similar items, according to invoices or equivalent documents. Conversion to U.S. dollars is based on the buyer exchange rate of Banco de la Nación Argentina from the business day prior to the invoice date.

It also confirms that eligible investments can be accumulated over the two-year period to reach the minimum amount.

6. Start-up and enjoyment of benefits

Article 6 allows the start-up of investments to occur after the two-year period, provided the investment was made within that period and is depreciable. Article 9 states that tax benefits apply in the fiscal year when the investment becomes operational, defined as its use in generating taxable income.

This is particularly useful for long-term projects such as industrial plants or complex equipment.

7. VAT refund and budget cap

Article 9 introduces a limit on early VAT refunds: the amount refunded cannot exceed 50% of the annual budget allocated to capital goods VAT refunds.

This cap may significantly affect the effectiveness of the benefit in practice. Allocation is based on the age of accumulated balances and, when equal, proportionally.

8. Firm debt as a cause for exclusion

Article 10 defines “firm, due, and unpaid debt” as debt that, after notification by the tax authority, has not been settled or appealed within the specified period. This allows taxpayers an opportunity to regularize their situation.

9. Pending issues

Several operational aspects remain pending regulation by the joint resolution, including certification of work progress, legal forms for non-profits, VAT refund documentation, and audit procedures.

Until then, companies can plan investments but cannot complete formal enrollment in the Regime.

10. Final reflection

Decree 242/2026 fulfills its regulatory function by clarifying access conditions, defining productive investments, and outlining benefits. It generally supports practical implementation, particularly through the accumulation of investments and flexible start-up timing.

However, the 50% VAT refund cap may limit the regime’s effectiveness in high-demand years. Overall, the regulation provides a necessary framework for SMEs to evaluate participation, pending further complementary rules.