New Law Amending Tax Procedure and Statute of Limitations

On December 26, 2026, the Argentine Congress passed a new law that introduces several changes to tax procedures. The changes include:

1. Increased penalties for breaching formal duties with the Argentine Tax Authority (ARCA)

The new Law substantially raises fines for violations of formal obligations, including:

•    Failure to file informative tax returns: for legal entities, fines now reach ARS 10,000,000, with higher amounts applicable under certain reporting regimes. 
•    For transactions between domestic parties and individuals, entities, or any other organization domiciled or incorporated abroad, the penalty for failure to report increases to ARS 11,000,000. For entities owned by foreign individuals or legal persons, fines rise to ARS 22,000,000.
•    The general penalty for failure to comply with formal obligations increases to ARS 500,000. Additionally, the maximum fine for breaches related to fiscal domicile rules, audit resistance, failure to provide data, and failure to keep supporting documentation for transfer pricing rises to ARS 35,000,000.
•    Minimum and maximum fines for failure to disclose applicable to one or more multinational groups are now ARS 6,000,000 and ARS 15,000,000, respectively. Furthermore, failing to submit the Country-by-Country Report or submitting it late, incomplete, or with mistakes will result in fines ranging from ARS 45,000,000 to ARS 67,500,000.
These amounts will be adjusted annually, starting January 1, 2027, based on the accrued variation of the Purchasing Value Unit (UVA) for the last calendar year. 


2. Reduced Statute of Limitations for Tax Assessments

•    The statute of limitations for ARCA to assess and collect taxes, as well as to enforce penalties and closures, is reduced to three years when the registered taxpayer has timely filed the relevant tax return and, where applicable, settled any resulting balance. ARCA may not challenge the return on the grounds of significant discrepancies between the reported information and data available in its systems or supplied by third parties.
•    Similar changes to limitation periods have been introduced in Laws 23660 (Social Security Funds), 23661 (National Health Insurance System), and 14236 (Restructuring of the Argentine Social Security Institute), with specific terms varying in each case.
•    Moreover, articles 2532 and 2560 of the Civil and Commercial Code have been reviewed to remove references allowing local jurisdictions to regulate tax limitation periods. It is now expressly established that, for taxes imposed by provinces, the City of Buenos Aires, and/or municipalities, the statute of limitations will be governed by the Argentine Tax Procedure Law 11683.


3. Optional Simplified Income Tax Regime

The Law introduces a simplified and optional filing mechanism for Income Tax for individuals and undivided estates resident in Argentina, provided they are not classified as large taxpayers and meet the income and asset thresholds set forth in the law.

Taxpayers opting for this simplified regime will have these benefits:

•    Accepting and paying the simplified return ARCA proposes will release the taxpayer from the obligation for that fiscal period, except where omissions, improper deductions, or fraudulent documentation are detected.
•    Income Tax and VAT returns for non-barred periods are presumed accurate, and no evidence to the contrary will be admissible. This benefit is forfeited if the ARCA challenges the return and identifies significant discrepancies between reported data and information available in its systems or provided by third parties. In such cases, the authority may extend audits to non-prescribed periods, determine taxable amounts ex officio, assess differences, and apply penalties under Law 11683.