Argentina: Changes to tax procedure law
Effective January 2, 2026
Law No. 27.799 (effective January 2, 2026) introduces several changes to the tax procedure law.
Updated thresholds and penalties
- Penalties for failing to submit tax returns (Art. 38 LPF) increase from $200* to $220,000 for individuals and from $400 to $440,000 for companies.
- For failing to submit informative tax returns for own or third-party information, fines originally set at $5,000 and $10,000 for foreign entities increase to $5 million and $10 million respectively.
- The penalty for failing to submit, or inconsistently submitting, the country-by-country (CbC) report, originally between $600,000 and $900,000, is raised to between $45 million and $67.5 million.
- The law provides that the amounts in Title I - Tax Criminal Regime - and Chapters I - Reforms to Law 11.683 - and III - Simplified Tax Return Regime - of Title II, will be adjusted annually starting January 1, 2027, considering the annual variation of the acquisition value unit (UVA) from January to December of the previous calendar year.
Reduced prescription periods for tax authority actions
Some prescription periods for tax authority actions are reduced, provided the taxpayer meets the required conditions.
Prescription periods under tax procedure law to govern provincial taxes
The Civil and Commercial Code of the Nation is amended to establish that, for taxes established by provinces, CABA (Autonomous City of Buenos Aires), and/or municipalities, prescription periods will be governed by the provisions of Tax Procedure Law 11.683.
Changes to simplified income tax regime
The simplified income tax regime will apply to individuals and deceased taxpayers residing in the country who opt for this modality, meeting the following conditions by December 31 of the year prior to exercising the option and during the two preceding fiscal years:
- Total income, taxed, exempt, and/or non-taxed by income tax, up to one billion pesos ($1,000,000,000).
- Total assets, including domestic and foreign assets, taxed, exempt, and/or non-taxed by personal property tax, not exceeding 10 billion pesos ($10,000,000,000).
- Not qualified as “large national taxpayers” according to the tax authority.
If the tax authority verifies that the taxpayer did not meet the requirements when adhering to the simplified income tax regime, it may exclude them from the regime and proceed with verification and/or inspection tasks for non-prescribed periods, determining the taxable matter ex officio, calculating any differences, and applying relevant sanctions according to Law 11.683.
Invitation to provinces to adopt simplified oversight regimes
Article 44 of the law invites provinces and CABA to adopt simplified oversight regimes in line with the provisions established in this law.
New thresholds for criminal offenses
Some of the new thresholds for configuring a criminal offense include:
- Simple evasion: Increased from $1.5 million to $100 million.
- Aggravated evasion: Increased from $15 million to $1 billion.
- For cases involving the use of fake invoices, the amount increased from $1.5 million to $100 million.
- For the undue appropriation of taxes, the threshold increased from $100,000 to $10 million monthly.
- Thresholds for offenses related to social security resources have also been modified.
- For simple evasion in social security resources, the threshold increased from $200,000 to $7 million monthly.
- For aggravated evasion, the threshold increased from $1 million to $35 million.
- The law also introduces a new mechanism for the elimination of criminal action, under which the tax authority will not initiate criminal actions if debts and their respective interests are settled. This benefit can be used only once by each individual and legal entity taxpayer.
For more information, contact a KPMG professional in Argentina:
Agostina Bermudez | agostinabeatrizbermu@kpmg.com.ar
* $ = Argentine peso