Through Law No. 27,799 (1), Argentina has enacted a new simplified regime—the first of its kind in its tax system—for personal income tax and undivided estates.

Antecedents

This country ranks among the world’s leading nations in terms of the amount of U.S. dollars held by taxpayers outside the financial system without being declared to the tax authorities (2).

This situation has arisen due to the historical instability of the financial system and the government’s occasional seizure of bank deposits in the face of the recurring financial crises that have occurred in the country (3).

Regularization of Assets

Tax amnesties, which were frequently implemented in the past, did not achieve the expected success for various reasons.

Given this situation, the government introduced a new and unprecedented simplified system for individual income tax, with the aim of bringing those funds into the formal economy to stimulate economic growth.

Tax Innocence

The rationale behind this extraordinary government regulation is that taxpayers adopted this evasive behavior in response to repeated economic crises and the confiscation of deposits; therefore, the aim is to regularize the assets of taxpayers designated by the regime as “fiscally innocent taxpayers.”

The authorities stated that this is neither a tax amnesty nor an asset regularization program, but rather a paradigm shift that moves away from the traditional presumption of tax guilt.

According to the authorities, taxpayers are now presumed innocent until the tax administration (ARCA) proves otherwise.

Simplified Income Tax Regime

Measures

The implementation of this system has the following characteristics:

1) Pro-Forma Tax Return: The tax authority calculates the tax in advance and provides the taxpayer with the corresponding tax return (4).

2) Tax calculation: It considers only taxable income and deductible expenses, and does not consider the taxpayer’s personal expenses or changes in net worth.

3) Eligibility: Individuals and undivided estates that meet the following requirements:

• a) Be a resident of the country
• b) Be registered for income tax
• c) Have income and net worth within the established limits
• d) not being classified as a high-income taxpayer by ARCA.
• e) The taxpayer’s registration must not be restricted or under review (CUIT).

Presumption of Accuracy

The filing of the tax return under this regime, together with payment made in a timely and proper manner, is considered final, unless there are significant irregularities.

The tax return is presumed to be correct; therefore, the tax authority may challenge it only if it has concrete evidence of significant irregularities—that is, those exceeding 15 percent. Taxpayers may also use previously undeclared savings, whether held domestically or abroad, without tax consequences (5).

The statute of limitations is reduced to 3 years.

Adjustment of the system

In light of the comments made, the Ministry of Economy is currently promoting an amendment to the system (6), the main objective of which is to expand access to it by reducing the grounds for exclusion, thereby providing greater legal certainty to those who decide to participate.

The proposed reform currently under consideration provides for:

• a) Expansion of the Taxpayer Base: Income and net worth limits for membership are eliminated.
• b) Large individual taxpayers and undivided estates: may participate.
• c) Significant discrepancy: its redefinition. (7)
• d) Burden of Proof, Corrections, and Presumptions in VAT: adjustments are made. (8)

Synthesis

Faced with the need to bring substantial hidden income and assets—both within their territories and abroad—into the formal economy, the countries in the region were compelled to normalize these situations in order to achieve sustained economic growth.

Undoubtedly, as long as these tax regularization programs do not aim to address the root causes and limit themselves to merely mitigating the consequences—as has been the case in most instances to date—they will be forced to repeatedly enact new tax amnesties (with varying degrees of ingenuity and success), thereby eroding the tax morale of compliant taxpayers.

Channeling economic resources from the underground economy into the formal economy is an urgent economic necessity, especially given its significant scale and the fact that emerging countries lack—or have limited access to—the legitimate financing needed for their economic development.

It is important that these regimes not become yet another tax within the system or a permanent “fiscal drain” that undermines tax compliance.

To avoid this situation, fiscal reform measures should be adopted that give rise to comprehensive tax models with a broad taxpayer base, segmented according to their ability to pay, but with a moderate and reasonable tax burden that prevents fiscal distortions and thereby enables economic development. (9).

Referencias:

1. Regulated by Decree No. 93/2026 and General Resolution No. 5820/2026.
2. These holdings are estimated at 170 billion dollars, second only to Russia, with an estimated total of 440 billion dollars.
3. By replacing them with government securities.
4. The taxpayer has the option to edit it and/or add information if they believe there is an error or if it is necessary.
5. Proof of enrollment is a positive factor for the financial system.
6. At a press conference held on July 22, 2026, the Minister of Economy announced the submission to Congress of the new bill updating the regime.
7. In the new project, the parameters and criteria are adjusted to maintain the accuracy of the system.
8. Among the measures, the burden of proof is shifted to the tax authority, and taxpayers are given an opportunity to file an amended return and pay the difference, thereby preventing that difference from being considered a “discrepancy” that would exclude them from the regime.
9. Limiting the numerous tax breaks that have been granted over time, which have gradually distorted the tax system.

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