22-12-2025

On December 18, 2025, the National Chamber of Deputies (lower house of Congress) granted preliminary approval to the Fiscal Innocence Bill, which was subsequently referred to the National Senate (upper house of Congress) for final enactment. Below is a summary of the most significant amendments introduced by the bill:

Simplified Tax Return Regime

Individuals and undivided estates that adhere to this regime will not be required to report changes in their net worth or expenditures, which would allow them to disclose previously undeclared assets (commonly referred to as “under-the-mattress dollars”).

In particular, the payment will have a release effect if the taxpayer accepts the content of the tax return proposed by ARCA and makes payment within the statutory deadline, except where income has been omitted, an improper deduction has been claimed, and/or false invoices or other fraudulent documents have been used.

Taxpayers with annual income of up to ARS 1 billion and assets of up to ARS 10 billion may adhere to the regime, provided they are not classified as “large national taxpayers.”

Increase in Penalties

The amounts of fines applicable to the late filing of tax returns and to other breaches of formal obligations regulated under the Tax Procedure Law are increased.

Increase in Criminal Liability Thresholds

The criminal liability thresholds under the Tax Criminal Regime are increased. In particular, the threshold for the offense of simple tax evasion is raised from ARS 1,500,000 to ARS 100,000,000, and from ARS 15,000,000 to ARS 1,000,000,000 for aggravated tax evasion.

Limitation on the Filing of Criminal Complaints

ARCA will refrain from filing a criminal complaint provided that the outstanding tax debts and accrued interest are fully paid, although this limitation may be granted only once per obligated individual or legal entity. If criminal proceedings have already been initiated, the criminal action will be extinguished if those obligations are settled by paying an additional 50% within 30 business days from notification of the charges.

ARCA will also refrain from filing a criminal complaint when, among other cases, the tax loss arises from differences in criteria related to statutory interpretation or technical-accounting aspects of tax assessment.

Reduction of the Statute of Limitation Periods

The statute of limitations for tax obligations is reduced from five to three years, provided that the tax return has been filed on time and, where applicable, the resulting balance has been duly settled, and provided that ARCA does not detect significant discrepancies. For non-registered taxpayers, the statute of limitations remains ten years.

Amendments to the Civil and Commercial Code and Other Provisions

The bill introduces the possibility of reduced statute of limitations periods under social security legislation, under conditions similar to those applicable to tax matters.

Additionally, it is clarified that local jurisdictions may not establish statutes of limitations periods different from those set at the national level.