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, […]
Buenos Aires Province Tax Collection Agency (ARBA) – New Collection Regime for Digital Wallets Through Regulatory Resolution 25/2025, ARBA established a new collection regime for the Gross Income Tax applicable to funds credited to payment accounts offered by Payment Service Providers Offering Payment Accounts (PSPOCPs). This collection regime will operate […]
Analysis of Decree 534/2025 – Total Veto of Bills 27.791, 27.792, and 27.793 1. Introduction and General Context Decree 534/2025, signed by the President of the Nation, exercises the authority granted under Article 83 of the National Constitution to fully veto three recently approved bills. These bills contained measures with […]