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Argentina Senate Passes ‘Inocencia Fiscal’ Tax Overhaul, Lifting Criminal Thresholds

Implementation now hinges on ARCA’s forthcoming regulations.

Overview

  • The upper house approved the measure 43–26 as part of the 2026 budget session, and the law now awaits promulgation and detailed regulation.
  • Criminal triggers are raised to $100 million for simple evasion and $1,000 million for aggravated evasion, with $200 million when responsibility is obscured and $100 million for false invoices, and amounts will index annually by UVA from 2027.
  • An optional simplified income‑tax regime for individuals and undivided estates (income up to $1,000 million and patrimony under $10,000 million) uses ARCA pre‑filled returns that, if accepted and paid, carry an efecto liberatorio except in cases like omitted income or apocryphal documents.
  • For compliant taxpayers the statute of limitations for many reviews falls to three years, and pending criminal cases may be extinguished once by paying the full debt, interest and a 50% surcharge within set terms.
  • After SME complaints about automatic fines, the government pledged to adjust the regulations to temper immediate penalties, while opponents and experts warn of money‑laundering and accountability risks.