Overview
- Ley 27.799 took effect upon publication in the Boletín Oficial, immediately reshaping the penal tax regime and fiscal procedures.
- Criminal thresholds rise sharply: tax evasion simple now triggers at ARS 100 million per tax and year, with aggravated evasion at ARS 1,000 million, alongside higher floors for other tax crimes.
- A one-time pre‑denunciation payment of the tax debt and interest prevents a criminal complaint, and ongoing prosecutions are extinguished if the debtor pays the debt, interest, and a 50% surcharge within 30 business days of notification.
- ARCA faces narrower grounds to file criminal charges, excluding cases rooted in interpretive disagreements, technical-accounting issues, uncorroborated legal presumptions, or when filings precede a formal audit notice.
- Compliant registered taxpayers gain a shorter three-year prescription period absent significant discrepancies, an optional ARCA-prepared simplified return becomes available to qualifying individuals, and all amounts will index annually by UVA from January 1, 2027 with ARCA publishing updated tables and provinces invited to align.