Executive summary

On 25 June 2026, Argentina's Chamber of Deputies approved a bill establishing the "Régimen de Incentivo para Grandes Inversiones en Nuevas Industrias" (Super RIGI) regime aimed at encouraging large-scale investments in new industries. The Super RIGI is an expanded version of the existing Incentive Regime for Large Investments (RIGI) created under Law No. 27,742 (For background, see EY Global Tax Alerts, Argentina enacts Bases Law and Tax Package, dated 8 July 2024; Argentina publishes decree implementing Incentive Regime for Large Investments, dated 26 September 2024). The bill has been sent to the Senate and is pending final legislative approval.

The proposal aims to create a comprehensive incentive framework targeting "new economic activities" defined as any industrial, technological or service-related project associated with strategic technological and digital infrastructure that has a transformational impact on Argentina's productive structure and is not currently developed, produced or provided in the country, or is only developed at an experimental or pilot stage.

The regime is intended to position Argentina as a destination for frontier sectors such as artificial intelligence, semiconductors, advanced biotechnology and digital infrastructure.

The regime would be available for five years following the date the regulatory decree is published in the Official Gazette; the Executive Branch may extend that deadline for one more year.

Access to benefits requires full adherence by provincial and local jurisdictions, without which incentives would not apply.

Requirements and characteristics of the investment plan

The Super RIGI would apply to large-scale projects meeting the following key criteria:

• Minimum investment of US$1b per project
• At least 20% of the investment committed within two years of approval
• Implementation through a dedicated Sole Purpose Vehicle (SPV) (Vehículo de Proyecto Unico or VPU)
• Activities must qualify as new economic activities (excluding expansions or upgrades of existing operations)

Tax incentives

Income tax

SPVs will be subject to a 15% income tax rate.

As an option, an accelerated amortization mechanism can be applied on certain investments, according with the following rules:

• Movable assets can be depreciated over at least two years.
• Infrastructure work, construction and fixed installations directly linked to the project may be depreciated either:
1. 60% in the fiscal year in which the relevant asset becomes operational and the remaining 40% in two equal and consecutive annual installments
2. In a number of equal annual installments determined by reducing the estimated useful life to 60% of its normal life

Net operating losses (NOLs) that cannot be absorbed by taxable profits from the same period may be carried forward indefinitely and deducted from taxable profits obtained in the following years. After five years, any remaining losses may be transferred to third parties. NOLs can be adjusted for inflation, based on changes in the Consumer Index Price (Indice de Precios al Consumidor or IPC).

Dividends and profit distributions paid by an SPV would be subject to a 7% tax rate. After four years from the adhesion date, the applicable rate would be reduced to 3.5%. Payments to foreign beneficiaries would be subject to withholding at those same rates.

Special rules for reorganizations and the deduction of financing costs.

Value Added Tax (VAT)

When the SPVs receive VAT invoices on investment in computable assets, the SPVs may pay the VAT with Tax Credit Certificates. In this case, the SPV cannot consider this VAT as input VAT in its returns. The certificates will be considered as free availability VAT credits for the suppliers (saldo a favor de libre disponibilidad in Spanish). If the tax authorities do not resolve a requested devolution or transfer within three months, the credits may be freely transferred to third parties without the tax authorities' authorization.

Tax on debits and credits in bank accounts

SPVs may claim an income tax credit for 100% of the amounts paid and/or collected for the tax on debits and credits in bank accounts.

Provincial and local tax limitations

Provinces and municipalities adhered to the Super RIGI regime would be subject to significant limitations. For example, they would not be able to settle new local taxes or increases in existing obligations; they would have a cap of 0.5% for Turnover Tax rate; and SPVs' documents would not trigger stamp tax.

Social security incentives

A flat 10% employer contribution rate would be applied for new hires related to the project. The Labor Assistance Fund (Fondo de Asistencia Laboral, in Spanish), if applicable, is not included in this fixed rate.

Customs incentives

SPVs' imports of capital goods (assets included in the approved inversion plan) shall be exempt from import duties, statistic fees and destination verification, as well as from any regime of reverse withholding, prepayment or withholding of national, provincial or municipal taxes.

Definitive exports of goods obtained under the promoted project, made by the SPVs, will be exempted from export duties.

Import and export regulatory restrictions are prohibited from being imposed.

Foreign exchange incentives

Export proceeds collected by the SPVs would be exempt from the obligation to be brought into and settled in the Argentine Official Foreign Exchange Market (Mercado Único y Libre de Cambios or MULC) in the following percentages, counted from the first export of the goods or services constituting the main purpose of the project:

• 20% of the proceeds after one year
• 40% of the proceeds after two years
• 100% of the proceeds after three years

These proceeds, to the extent of the percentages above, would be freely available to the SPVs.

In addition, SPVs should not be required to bring into or settle in the MULC foreign currency derived from other project-related transactions, including capital contributions, external financing and other financial inflows.

Restrictions on access to foreign exchange for debt repayment, dividend distributions and profit remittances should not apply.

Stability

SPVs adhering to the Super RIGI would benefit from 30-year stability in tax, customs, social security and foreign exchange matters.

Implications

When enacted, the Super RIGI could significantly enhance Argentina's attractiveness for large-scale greenfield investments in new industries.

For multinational enterprise groups, the proposed 15% income tax rate, reduced dividend withholding rates, unlimited loss carryforward, VAT relief, customs exemptions and broad foreign exchange flexibility could materially affect projected effective tax rates, investment timing, financing structures and repatriation planning.