On December 30, 2025, Argentina enacted Law No. 27,799 through Decree 933/2025, introducing significant reforms to its tax enforcement framework. The law establishes a taxpayer-friendly approach by reinforcing “fiscal innocence.”1,2
WHY THIS MATTERS
Law No. 27,799, enacted through Decree 933/2025, marks a turning point in Argentina’s tax enforcement strategy. It reinforces taxpayer-friendly presumptions, introduces a liberating accuracy presumption under the Simplified Income Tax Return, modernizes limitation periods, and significantly raises criminal tax thresholds. The reform aims to reduce unnecessary disputes and concentrate audits where objective evidence indicates material discrepancies, creating a more predictable environment for compliance and planning.
Overview of the Law
The Law shifts from “presumed of fiscal culpability” to an evidence based approach focused on materiality.
Key Highlights
Simplified Income Tax Return
- For individuals and estates, Chapter III creates an optional Simplified Income Tax Return. When a taxpayer opts in, accepts the computation proposed by Agencia de Recaudación y Control Aduanero (ARCA), and pays on time, the return benefits from two protections:
- an accuracy presumption
- a liberating effect for that period
- In practice, this “fiscal cap” shields filed periods from being re‑opened, except where a “significant discrepancy” is identified.
- “Significant discrepancy” is defined objectively. It exists when the adjustment increases tax due or reduces losses/credits by at least fifteen percent; when the difference exceeds ARS 100,000,000 (CTR Art. 1); or when false/apocryphal documentation is used and not rectified or paid with interest.
- Notably, Article 18(f) of Law 11,683 (unjustified net worth increase) does not apply when assessing discrepancies in income tax and VAT. When the presumption holds, the taxpayer is released from civil actions, criminal tax/customs liability, and administrative infringements.
Limitation Periods
Aligned with compliance, the general limitation period is five years for registered taxpayers, which may be reduced to three years if the return was filed and the balance paid on time and no significant discrepancy is raised. The period is ten years for non‑registered taxpayers; specific rules apply for tax credits and for withholding/collection agents.
Criminal Tax Regime
Thresholds are updated by orders of magnitude, for instance, simple evasion is now ARS 100,000,000 per tax and fiscal year, and aggravated evasion by amount is ARS 1,000,000,000 – with annual UVA indexation from January 1, 2027. Regularization mechanisms are also refined: ARCA will not file a criminal complaint if principal and interest are paid before the complaint (once per taxpayer), and any criminal action already initiated will be extinguished upon full payment plus an additional fifty percent within thirty business days of notification of the charge.
Administrative Penalties
The Law also updates the amounts of penalties established in Law 11,683 (Tax Procedure). For example, the fine for failure to file a tax return increased from ARS 200 to ARS 220,000 for individuals, and from ARS 400 to ARS 440,000 for legal entities.
Foreign Currency & Wealth Reporting
The reform indirectly affects foreign currency holdings and wealth reintegration. While the law removes the presumption of unjustified net worth increases for simplified returns, existing banking and registry controls remain. Taxpayers must still justify the origin of funds for registrable assets (e.g., real estate, vehicles), and restrictions on deposits and transfers persist under financial compliance rules.
KPMG INSIGHTS
KPMG in Argentina states that:
Our role as KPMG is to review ARCA’s proposed data and perform the necessary estimations to help maintain accurate filings. Under the new framework, employers and assignees should go beyond compliance by maintaining robust documentation of assignment-related benefits, helping support full alignment between payroll and tax returns, and recalibrating criminal-risk matrices to reflect updated thresholds and “no-complaint” criteria. It is also essential to strengthen supplier and receipt validation to prevent exposure to apocryphal documentation.
For companies with globally mobile employees, this reform creates an opportunity to reassess benefit structures, shadow payroll processes, and cross-border reporting, while considering whether the optional Simplified Income Tax Return could be a practical solution for certain assignees. More broadly, the trend toward greater flexibility in enforcement should be factored into strategic mobility planning, as it may enhance Argentina’s attractiveness as a destination. Now is the time to evaluate the compliance framework and mobility policies to help maintain readiness and take advantage of these changes for risk mitigation and operational efficiency.
If assignees and/or their programme managers have any questions or concerns about the scope of the update, its application and potential impacts, and appropriate next steps, they should consult with their qualified tax professional or a member of the GMS tax team with KPMG in Argentina (see Contacts section).
FOOTNOTES:
1 Presidencia de la Nacion, Republica Argentina (in Spanish), “DECTO-2025-933-APN-PTE - Promúlgase la Ley Nº 27.799.”, published on January 2, 2026.
2 AFIP (Administración Federal de Ingresos Públicos), National tax and customs authority (in Spanish), “Inocencia Fiscal”, published on December 30, 2025.
Contacts
Disclaimer
The information contained in this newsletter was submitted by the KPMG International member firm in Argentina.
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