Argentina regulates Fiscal Innocence II law

The Argentine government has issued Decree 1253/2026, regulating the Fiscal Innocence II Law. The new regulations aim to simplify access to the regime by replacing previous wealth and turnover limits with a single requirement of fiscal residency throughout the period.

Under the new rules, a “significant discrepancy” is identified if the tax agency, ARCA, detects an increase in determined tax or a reduction in tax losses of at least 15% compared to the taxpayer's declaration. Discrepancies involving fraudulent invoices or improper income will be considered significant regardless of the amount. Taxpayers may avoid this classification by filing an amended return within 15 business days of notification, provided all resulting balances and interests are paid.

Adherence to the regime provides a “presumption of accuracy” for income and VAT declarations for non-prescribed periods. While the law offers a “liberatory effect,” its full effectiveness depends on provincial adherence. Experts note that further adjustments to UIF regulations and reporting applications for large taxpayers may be required, potentially necessitating deadline extensions.