TAX

16-4-2026

REGULATIONS OF THE INCENTIVE REGIME FOR MEDIUM-SIZED INVESTMENTS (RIMI)

Through Decree 242/2026, the National Executive Branch regulated the Incentive Regime for Medium-Sized Investments (RIMI) created by Law 27,802, aimed at SMEs carrying out productive investments (the acquisition or manufacture of depreciable movable assets and the execution of works directly allocated to the development of productive activities within the country) within a period of two (2) years.

The RIMI grants tax benefits consisting of accelerated depreciation for invested fixed assets and early refund of VAT input credit balances.

The minimum investment amounts required are as follows:

  • Micro-enterprises: USD 150,000
  • Small Enterprises: USD 600,000
  • Medium-sized Enterprises – Tier 1: USD 3,500,000
  • Medium-sized Enterprises – Tier 2: USD 9,000,000

Notwithstanding the above, RIMI also includes investments in irrigation systems and/or equipment, anti-hail nets, high energy-efficiency assets, and livestock assets, regardless of the investment amount.

Below is a summary of the main provisions of Decree 242/2026:

Effective Term

The productive investments covered by the RIMI are those made as from March 6, 2026 (the effective date of Law 27,802) and up to a period of two (2) years counted from the effective date of the joint resolution that will establish the necessary rules for the effective implementation of the regime.

Eligible Beneficiaries

In order to qualify as beneficiaries of the RIMI, entities must hold a certificate evidencing, at the beginning of the fiscal year in which the first productive investment is made, their status as a Micro, Small, or Medium-sized Enterprise – Tier 1 or 2.

Alternatively, they may also qualify as non-profit organizations which, even without such certificate, are registered with the Revenue and Customs Control Agency (ARCA) under any of the legal forms determined by ARCA, provided they meet the parameters applicable to Micro, Small, or Medium-sized Enterprises – Tier 1 or 2.

Depreciable Movable Assets

Depreciable movable assets” are defined as new assets — excluding automobiles — that have been acquired, produced, manufactured, and/or imported, provided they are classified, pursuant to Annex I of Decree 557/2023 (or any future replacement), as Capital Goods (BK) or Information Technology and Telecommunications Goods (BIT).

Agricultural Irrigation Systems and/or Equipment

Agricultural irrigation systems and/or equipment” refers to investments aimed at the acquisition, installation, and/or development of new depreciable movable assets intended to improve water resource management, optimize water distribution, and enhance agricultural productivity through precision technology.

Anti-Hail Nets

Anti-hail nets” are high-density polyethylene or similar mesh fabrics, with a minimum resistance to hail impact of 20 mm and ultraviolet protection, as well as the associated support structures intended to protect agricultural crops.

High Energy-Efficiency Assets

High energy-efficiency assets” are investments intended for:
(i) the acquisition, installation, and/or development of depreciable movable assets that generate, store, and/or transport electricity from renewable energy sources throughout the national territory; or
(ii) the optimization, recovery, or reduction of energy consumption in production units.

Livestock Assets

Depreciable livestock assets” are animals intended for breeding purposes with superior genetics, whether pedigree or controlled purebred, registered with producer associations established for such purpose or with genetics supply companies, to be directly allocated to the development of productive activities within the national territory.

Works

Works” are understood as the proportion of investments made within the two (2)-year period, insofar as they are allocated to the activity of the beneficiary entities, including the movable assets that form an inseparable part thereof and/or complement them, as well as the expenses incurred in connection with their installation.

Included are those works which, as of March 6, 2026, have a degree of progress of less than 30% of the total investment amount.

Start-Up

Productive investments carried out during the term of the RIMI may become operational after the expiration of the two (2)-year period, provided that, at the time such investments are made, it is evidenced that they are eligible for depreciation for income tax purposes.

Excluded Investments

Investments made in financial and/or portfolio assets (such as shares, equity interests, mutual fund units, certificates of participation in financial trusts, digital currencies, securities, bonds, and other instruments) shall not be considered productive investments.

Use of Benefits

The tax benefits established under the RIMI shall apply in the fiscal year in which the productive investment becomes operational, provided that, where a minimum investment amount is required, such threshold has been met within the two (2)-year period.

Exclusions

With respect to exclusion from the RIMI for those with final, due, and unpaid tax, customs, or social security debts, “final, due, and unpaid debt” shall be understood as debt which, having been formally demanded by the tax authority, has not been regularized or challenged by the taxpayer within the period granted in such notice, counted from its notification.

Supplementary Regulations

ARCA, jointly with the Secretariat of Agriculture, Livestock and Fisheries and the Secretariat of Energy, shall issue the supplementary, clarifying, and operational rules necessary for the effective implementation of the RIMI.

 

Carlos R. Anavia

Tax Director

Tax Department

April 2026

 This newsletter has been prepared by Jebsen & Co. for the information of clients and friends. Although it has been prepared with the greatest care and professional zeal, Jebsen & Co. does not assume responsibility for any inaccuracies that this bulletin may present.