RIMI Underway: Joint General Resolution 5849/2026 Activates Benefits For Medium-Sized Enterprises

Regulation of the RIMI: Joint General Resolution 5849/2026

ARCA – Secretariat of Energy – Secretariat of Agriculture, Livestock and Fisheries

Published in the Official Gazette: May 19, 2026

By María Soledad González

  1. Executive Summary

Joint General Resolution 5849/2026, issued by the Customs and Tax Collection and Control Agency (ARCA), the Secretariat of Energy, and the Secretariat of Agriculture, Livestock and Fisheries, regulates certain operational aspects of the Incentive Regime for Medium-Sized Investments (RIMI), created under Title XXIII of Law No. 27,802 and regulated by Decree No. 242/2026.

The resolution establishes the exclusive digital channel for managing the regime (the Investment Management System – SGI), specifies the requirements and conditions beneficiaries must meet—both SMEs and nonprofit entities—defines the mechanism for proving productive investments not subject to minimum investment thresholds and the degree of completion of works, and organizes the supervisory and auditing powers among the three participating agencies.

Its publication marks a key milestone: this regulation triggers the beginning of the two-year period during which companies may carry out eligible investments and obtain the benefits of accelerated depreciation for Income Tax purposes and refunds of VAT tax credits.

  1. Background and Regulatory Context

The RIMI was conceived as a complement to the Incentive Regime for Large Investments (RIGI), aimed at covering Micro, Small, and Medium-Sized Enterprises that, due to their scale, could not access that regime. Title XXIII of Law No. 27,802—known as the Labor Modernization Law—created the RIMI.

Decree No. 242/2026, published on April 13, 2026, regulated the substantive aspects of the regime: it defined depreciable movable assets, clarified the concept of productive works, established minimum investment amounts by company category (from USD 150,000 for microenterprises up to USD 9,000,000 for medium-sized enterprises, section 2), and imposed a cap of 50% of the budget allocation for VAT tax credit refunds.

However, Article 11 of the Decree delegated the issuance of a joint resolution by ARCA, the Secretariat of Energy, and the Secretariat of Agriculture, Livestock and Fisheries within 30 calendar days of publication, in order to establish supplementary, clarifying, and operational rules. Joint Resolution 5849/2026 is precisely that regulation. Its publication enables the regime to become fully operational.

  1. Analysis of the Joint Resolution

3.1 Processing of Benefits: the Investment Management System (Article 1)

Article 1 creates the central interaction mechanism between beneficiaries and the State: the Investment Management System (SGI), a web platform to be implemented by ARCA. Through this system, all RIMI procedures will be handled: registration of investments, selection of tax benefits, and overall administration of the regime.

This implies that all procedures will, in principle, be digital, consistent with ARCA’s broader effort to digitize tax procedures. ARCA must still announce the effective launch date of the SGI and the technical specifications of the system.

3.2 Beneficiaries: Requirements and Conditions (Article 2)

Article 2 develops and clarifies the conditions required to qualify as a beneficiary, distinguishing between two groups:

  1. a) Micro, Small, and Medium-Sized Enterprises (SMEs). These companies must hold a valid SME Certificate on the first day of the month in which the fiscal year begins and during which the first investment is made, and must be registered in ARCA’s Registry System as Micro, Small, or Medium-Sized Enterprises (sections 1 and 2). For companies making their first investment during their initial fiscal year of operations, the SME Certificate must be valid at the time the investment is made.

This timing requirement is significant: it is not enough to have the certificate at the time of requesting the benefit; it must already be valid at the beginning of the fiscal year in which the investment is made.

  1. b) Nonprofit entities. Entities that cannot obtain an SME Certificate (associations, foundations, mutual societies, and other civil entities) must apply for qualification before the Secretariat of Industry, Commerce, and Small and Medium-Sized Enterprises, complying with Resolution SEyPyME No. 220/2019, and expressly authorize ARCA to transmit the declared information to that Secretariat.

Once qualified, ARCA will assign specific registration codes in the Registry System. The classification will remain valid until the last day of the fourth month following the end of the entity’s fiscal year. If the first investment is not completed within that period, the process must be restarted.

3.3 Productive Investments Not Subject to Minimum Amounts (Article 3)

Under Article 181 of Law No. 27,802, certain investments are exempt from minimum investment requirements. Article 3 establishes that the Secretariat of Energy and the Secretariat of Agriculture, Livestock and Fisheries will define the eligible assets in this category by issuing sector-specific regulations.

These include investments in irrigation systems and equipment, high energy-efficiency assets, anti-hail netting for the agricultural sector, and livestock assets. Lists of eligible assets will be available on ARCA’s website.

For investments not directly included on the lists but considered eligible by taxpayers, the regulation requires the submission of a report prepared by a qualified professional with a certified signature. These investments may then be evaluated by the competent Secretariat.

3.4 Proof of Progress in Construction Works (Article 4)

Article 4 of Decree 242/2026 provided that projects with a degree of completion below 30% of the total investment amount at the time the Law entered into force would be eligible under the regime. The joint resolution now establishes the documentation required to prove such progress, including:

– Invoices or equivalent documents supporting invested amounts.
– Technical reports prepared by qualified professionals with certified signatures.
– Certificates of construction progress.
– Construction contracts.
– Any other reliable evidence supporting the valuation of improvements to the property.

All documentation must be uploaded through the SGI.

3.5 Supervision, Noncompliance, and Penalties (Articles 5 and 6)

The resolution establishes a two-level control system. ARCA will verify the absence of enforceable tax debt when beneficiaries request access to the benefits. This means that before enjoying accelerated depreciation or VAT refunds, companies must not have unpaid tax, customs, or social security obligations.

The Secretariat of Energy and the Secretariat of Agriculture, Livestock and Fisheries may also conduct audits and inspections to verify compliance with regulations issued within their respective jurisdictions. These Secretariats will have access to the SGI to obtain relevant information.

If a breach is detected that could result in the revocation of RIMI benefits, the Secretariats must notify ARCA, which may then reclaim refunded VAT credits and/or unpaid Income Tax amounts, together with interest and penalties under Article 187 of Law No. 27,802.

  1. Effective Date

The resolution entered into force on May 19, 2026, the date of its publication in the Official Gazette. This date is important because, pursuant to Article 1 of Decree 242/2026, the two-year period for making eligible investments is calculated from the entry into force of this joint resolution. Therefore, the period runs from May 19, 2026 through May 19, 2028, without prejudice to productive investments made since March 6, 2026 also being included.

  1. Practical Implications

5.1 Verify the SME Certificate. Companies evaluating productive investments should ensure their SME Certificate is valid before making investments.

5.2 Register in the SGI as soon as it becomes available. ARCA will implement the SGI as the digital platform through which the entire regime will be managed.

5.3 The two-year period has already begun. Investments must be made before May 19, 2028.

5.4 Maintain tax compliance. ARCA will verify that beneficiaries do not have enforceable tax, customs, or social security debts.

5.5 Agricultural and energy-efficiency investments are exempt from minimum amounts. Investments in irrigation systems, high energy-efficiency assets, anti-hail netting, or livestock are not subject to the general minimum investment thresholds.

5.6 Document progress on ongoing projects. Companies with productive works that were less than 30% complete as of March 6, 2026 may include them in the regime but must properly document their progress.

5.7 Nonprofit entities: special procedure. Associations, foundations, mutual societies, and civil entities unable to obtain an SME Certificate must apply separately before the Secretariat of Industry and Commerce.

  1. Conclusion

With the publication of Joint General Resolution 5849/2026 and the implementation of the SGI by ARCA, the tax incentive regime for medium-sized productive investments becomes operational.

For SMEs and nonprofit entities planning productive investments over the next two years, the RIMI offers significant tax benefits—accelerated depreciation for Income Tax purposes and VAT tax credit refunds—which may improve project profitability. The key will be careful planning, compliance with formal requirements, and close attention to supplementary regulations yet to be issued.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal, tax, or investment advice. Each case requires individual analysis under applicable regulations.