[REVISION HISTORY]

Argentina enacts and regulates Inocencia Fiscal II reform

Updated 37 times since CLSTR started tracking revisions of this situation.

What changed

2026-10-11 20:52 UTC → 2026-10-23 14:48 UTC · added ~~removed~~

The Argentine government has promulgated Law 27.826, known as ‘Inocencia Fiscal II’, to encourage the formalization of undeclared savings, such as ‘mattress dollars’, into the formal economy. The law modifies the Tax Criminal Regime and the Tax Procedure Law, eliminating previous income and asset caps for the simplified Ganancias (Income Tax) ~~regime—previously set at $1 billion and $10 billion respectively.~~ regime. To encourage compliance, the law establishes a presumption of accuracy for tax returns under this regime. It defines ‘significant discrepancies’ that allow the Agency of Collection and Customs Control (ARCA) to challenge declarations, specifically when a challenge results in a tax increase or loss reduction of at least 15%. Recent ~~regulations for the law~~ regulations, including Decree 1253/2026, have introduced specific tax evasion thresholds: simple evasion is set at $100 million, while aggravated evasion reaches $1,000 million. Starting in 2027, these amounts will be adjusted annually by UVA. Furthermore, prescription periods for taxpayers with good fiscal behavior will be reduced from five to three years for national taxes, and from ten to five years for social security resources. The ~~law~~ regulations also replace previous wealth and turnover limits with a single requirement of fiscal residency. Taxpayers may avoid a ‘significant discrepancy’ classification by filing an amended return within 15 business days of notification, provided all resulting balances and interests are paid. While the law provides relief for MiPyMEs, individuals, and non-profit entities by reducing certain formal non-compliance ~~fines by 25%, with a 50% reduction available for certain prior infractions if the underlying obligation is met. However,~~ fines, legal and accounting experts have raised concerns regarding potential conflicts with anti-money laundering regulations. ~~While the law seeks to formalize undeclared cash, professionals~~ Professionals remain obligated to perform due diligence and report suspicious activities to the Financial Information Unit (UIF).

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