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 […]
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 […]
Analysis of the Simplified Sworn Tax Return Regime Approved by the Fiscal Innocence Law 1. Preliminary considerations Law No. 27,799, known as the “Fiscal Innocence Law,” introduces, through Chapter III, a Simplified Sworn Tax Return Regime for Income Tax (the “Regime”), applicable to individuals and undivided estates that meet certain […]
Fiscal Innocence Law and the Reform Introduced to Law No. 11,683 I. Introduction The enactment of Law No. 27,799, known as the “Fiscal Innocence Law,” introduces structural amendments to Law No. 11,683, directly altering the regime of infractions, penalties, and statutes of limitations. Below is an analysis of the main […]
Fiscal Innocence Law: Relevant Changes in the Application of the Tax Criminal Regime I. Introduction Last Friday, December 27, Congress passed Law No. 27,799, known as the “Fiscal Innocence Act”, which, among other amendments, introduces significant changes to the Tax Criminal Regime (Régimen Penal Tributario – RPT). The approved […]
Analysis of ARCA General Resolution 5798/2025 Transfer Pricing and International Transactions. Increase in the thresholds for information reporting (Amendments to General Resolutions 4717 and 5010) Key changes introduced by General Resolution 4717 (general regime) 1.1. Increase in thresholds that trigger reporting obligations General Resolution 5798/2025 introduces amendments to the transfer […]
Important precedent: services rendered outside Argentina but used in the country – their non-taxability for Income Tax purposes The National Tax Court (Chamber B) has issued a particularly significant ruling for all companies that outsource operational services abroad. In the case of DirectTV Argentina S.A., ARCA made an ex officio […]
Moratorium Law 6842 CABA and AGIP Resolution 461/25 Through Law No. 6,842, published on September 23, 2025, the Legislature of the Autonomous City of Buenos Aires approved a new Tax Regularization Regime (the “Regime”) applicable to all taxes administered and collected by the Administración Gubernamental de Ingresos Públicos (“AGIP”). Starting […]
Reinstatement of the procedure for refunding advance payments of the PAIS Tax: General Resolution ARCA 5765/2025 The Tax Collection and Customs Control Agency (ARCA) established, through General Resolution 5765/2025, the reinstatement of the special procedure for the refund of advance payments of the PAIS Tax that could not be credited […]
Reform of the Tax Balance Compensation Regime: Analysis of ARCA General Resolutions 5753/2025 and 5754/2025 The Tax Collection and Customs Control Agency (ARCA), through General Resolutions 5753/2025 and 5754/2025, has established a new comprehensive regime for the compensation of tax obligations. These rules replace and update the existing regulatory framework, […]