Executive summary

On 2 January 2026, the Argentine Government enacted Law No. 27,799 (referred to as the Tax Innocence Law or the Law) through publication in the Official Gazette.

The Law provides, among other measures, an increase in the thresholds to apply penalties under the Criminal Tax Law, an increase in the penalty amounts imposed under the Tax Procedural Law, and a reduction in the statute of limitations for taxes and social security contributions in certain situations.

The main updates incorporated by the Law are described below.

Criminal Tax Law Regime

The Law increases the minimum thresholds from which tax evasion becomes subject to penalties under this Regime. The following table shows the updated thresholds, with amounts in Argentine pesos (ARS):

Tax authorities should not file a criminal complaint if the taxpayer pays the total amount of the evaded taxes and corresponding interest before the complaint is filed; this limitation applies only once per individual or entity.

If criminal proceedings have started, they may be extinguished if the taxpayer unconditionally and fully pays the evaded amount, the interest and an additional 50% of the total amount, within 30 business days from the notification of the criminal charge.

Furthermore, the Law clarifies and specifies that the tax authorities will not file criminal complaints in certain situations, such as if it is clear that there has been no punishable conduct, in cases of interpretative differences if the taxpayer has disclosed its interpretative and/or technical-accounting position through a formal submission before or together with the tax return, among others.

Tax Procedural Law

The Law updates the penalties for failure to file tax returns and for other formal obligations under Tax Procedural Law No. 11,683. The main updates (in Argentine pesos) are as follows:

Penalties under article 38 and its supplementary provisions — Law 11,683:

Penalties under articles 39, 40 and its supplementary provisions — Law 11,683:

Statute of limitations

The Law maintains the five-year statute of limitations for registered taxpayers, during which period the tax authority may determine and require the payment of taxes, as well as impose and enforce fines and closure of premises.

However, in a new provision, the Law establishes that the statute of limitations will be reduced to three years if the taxpayer submits the corresponding tax return on time and settles the balance, provided that the return is not challenged due to a "significant discrepancy" detected between the submitted information and the data available to the tax authority.

For these purposes, a "significant discrepancy" will be understood to exist if at least one of the following conditions is met:

• The adjustment made by the tax authority results in an increase in taxes or a reduction in losses or balances in favor of at least 15% compared to what was declared by the taxpayer.
• The difference between the tax declared and the tax determined by the tax authority in the adjustment exceeds ARS100m (approx. US$68k); this amount is subject to annual adjustment.
• An adjustment made by the tax authority due to the use of false invoices results in an increase in taxes or a reduction in losses or balances in favor.

A similar rule applies to the statute of limitations on Social Security contributions.

All the amounts mentioned in this Alert will be adjusted annually, as of 1 January 2027, considering the annual variation of the Purchasing Value Unit (UVA) from January to December of the calendar year immediately prior to the adjustment.

Implications

Multinational companies should ensure proper preparation and timely filing of their tax returns to reduce risks associated with these heightened penalties and to benefit from shorter statutes of limitations for tax and social security matters.