New Tax Regularization Regime in Buenos Aires City: Benefits and Deadlines for Enrollment – Barreiro

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 November 3, 2025, taxpayers will have a 90-day period to adhere to the Regime, ending on January 31, 2026 (inclusive). This term may be extended once for an equal period, as determined by AGIP.

AGIP Resolution 461/25 (BOCBA No. 7233, dated October 24, 2025, hereinafter the “Regulation”) implements the law and details its operational aspects, setting forth the conditions for enrollment, financing rates, installment calculation formulas, forgiveness scales, and cases of expiration.

1.- General Scope

Taxpayers or those responsible for obligations due or infractions committed up to and including August 31, 2025, may adhere under the regulatory conditions.

The Regulation establishes that the procedure must be carried out exclusively through AGIP’s website using Clave Ciudad miBa Level 3, and adherence becomes effective upon payment in full or of the first installment. Jointly liable parties may also adhere, even if the principal debtor is excluded from the Regime.

Enrollment may be total or partial; however, in the case of judicial debt, it must be total. Furthermore, adherence interrupts the statute of limitations period on the declared debt, regardless of the validity of the enrollment. The new statute of limitations will begin on January 1 of the year following the end of the period granted for payment.

2.- Exclusions

The following may not adhere:

Individuals or entities declared bankrupt without continuation of business operations.
Those convicted of crimes under National Law 24,769 and its amendments, or the Criminal Tax Regime approved by Title IX of National Law 27,430.
Collection agents for withheld but unpaid amounts.
Payment plans in force as of 08/31/2025 that previously included interest forgiveness.

The Regulation also provides that bankrupt or reorganized taxpayers with business continuity may adhere with judicial authorization and the trustee’s consent.

3.- Judicial Debts and Precautionary Measures

“Judicial stage” refers to debts under ongoing tax enforcement proceedings. Taxpayers must withdraw their legal actions and accept the total amount claimed.

Adherence suspends procedural deadlines and entails the lifting of precautionary measures. During the Regime’s validity, AGIP will refrain from requesting new measures unless the statute of limitations expires within 30 days.

The Regulation clarifies that withdrawal is deemed perfected upon enrollment in the plan.

4.- Criminal Effects

Adherence suspends criminal proceedings and the criminal statute of limitations. Full payment of the debt extinguishes criminal action, while plan expiration reactivates it.

The Regulation establishes that AGIP will refrain from filing criminal complaints regarding obligations included in the Regime.

5.- Costs and Attorneys’ Fees

Enrollment regarding judicial debts entails payment of legal costs and attorneys’ fees, calculated based on the regularized debt plus interest.

Fees are calculated in UMAs (Law 5,134), with a minimum of 1 UMA and a maximum of 10% of the debt, payable in up to six installments, plus VAT when applicable.

6.- Tax Benefits and Payment Plans

Surcharges, fines (formal and substantive), and other penalties for infractions committed up to 08/31/2025 that remain unpaid and unfinalized at the law’s effective date are forgiven, provided that the principal obligation is or has been paid.

Plans may extend up to 48 installments with forgiveness of up to 100% of compensatory or punitive interest.

Different forgiveness scales are established according to taxpayer type and timing of adherence: general taxpayers may receive up to 100% interest forgiveness if adhering within the first 30 days, while large taxpayers may receive up to 70%, decreasing progressively thereafter.

Reformulation of existing plans is allowed, except for those that already granted prior benefits.

7.- Other Provisions

Obligations may be paid with embargoed funds.

The financing interest rate is set at 3% monthly on balances for taxpayers included in the Continuous Verification System for Large Taxpayers (Res. 161/AGIP/19) and 2% monthly for all others.

The Regulation clarifies that the rate applies monthly to outstanding balances throughout the plan and uses the French amortization formula for installment calculation.

The plan will expire for failure to pay two installments, consecutive or alternating, or non-payment within 60 days of their due date.

Those who adhere will be automatically included, if not already, in the Electronic Tax Domicile and electronic bill systems, through which all notifications related to the Regime will be made.

📄 The full text of the Law can be found in the Official Gazette of the City of Buenos Aires No. 7210, dated September 23, 2025, and the implementing Resolution in Official Gazette No. 7233, dated October 24, 2025.