Benefits and Implications of the New Tax Moratorium

Law 6842, published in the Official Gazette on September 23, 2025, established a new regime to regularize tax debts whose application, collection, and auditing are the responsibility of the City of Buenos Aires Tax Authority (AGIP). This Law was regulated through Resolution 461/AGIP/2025, published in the Official Gazette on October 24, 2025.

This regime applies to tax obligations of any nature due up to August 31, 2025, which are subject to administrative or judicial^[1] proceedings, as well as to infringements committed up to that date. Obligations that have been settled under other payment plans may also be included. However, article 4 of the Law establishes excluded cases.^[2]
 

Taxpayers or responsible parties may enrol until January 31, 2026, inclusive. AGIP may extend this deadline once.
 

1. Requirements  

Taxpayers must declare the tax obligations owed, in whole or in part, within the deadlines set for acceptance. In the case of obligations under tax enforcement proceedings, the settlement must be formulated by trial and include the total amount of the debt enforced. The rights and legal actions initiated against the City of Buenos Aires Government (GCBA) in relation to such debts must be waived.

Taxpayers must also pay either the total amount of the debt in cash or the first instalment on its due date, without delay. In the case of payment plans, they must state the bank account number of the account from which the instalments will be debited.

2. Tax benefits

a. Taxpayers will obtain the automatic remission of all fines that would apply to them for breaches of material duties committed up to August 31, 2025, as well as unpaid fines without final judgment as of the entry into force of the regime (November 3, 2025), provided that the related tax obligations are settled under the regime.

b. They will also obtain the automatic remission of all applicable formal fines and all imposed but unpaid fines that, as of the date of entry into force of the regime, have not had a final judgment, provided that the omitted formal duty has been fulfilled within the period to take advantage of the regime. When the duty cannot be fulfilled after committing the infraction, the fine is waived ex officio, provided that the offense was committed before August 31, 2025.^[3]

c. Taxpayers who adhere will obtain the cancellation of compensatory and punitive interest on obligations regularized under the regime, in accordance with their category, the payment method, and the time elapsed since the entry into force of the regime.

Percentages of forgiveness of compensatory and punitive interest
Time period to be counted in calendar days	Large Taxpayers (Resolution 161-AGIP/19)		Taxpayers not included in Resolution (161-AGIP/19)
	Cash Payment	Payment Plan [4]	Cash Payment	Payment Plan[5]
Up 30 days	70%	60%	100%	70%
31–60 days	60%	40%	70%	60%
61–80 days	40%	30%	50%	40%
After 81 days	30%	10%	40%	30%

 

d. Finally, taxpayers will obtain full settlement of the debt under the conditions established in the regime, which results in the extinction of criminal proceedings

3. Effects of joining the regime

Adhering to this regime will cause:

a. Complete and unconditional acceptance of the tax authority's claim to the extent that the matter was intended to be regularized.

b.  Waving the right to recover all or part of the declared tax and/or interest and/or fines, as well as waving any action and right relating to administrative and judicial proceedings in progress.

c. The suspension of ongoing criminal proceedings and the statute of limitations, as well as the interruption of the statute of limitations for determining liens, applying fines, and demanding payment of the declared debt.

d. In the case of debts in tax enforcement proceedings: (i) the lifting of imposed preliminary injunctions and (ii) the taxpayer’s and/or responsible party’s obligation to pay the fees of the agents involved, expenses, and court fees.