The Chief of Staff, Manuel Adorni, announced via text in X that the decree calling for extraordinary sessions from December 10 to 31 would soon be published in the Official Gazette. The agenda consists of six initiatives starting with the 2026 budget bill and ending with the reforms announced by Javier Miley.
The first issue that the national government seeks to approve is the 2026 budget. The second point on the agenda of the special sessions is the draft tax patent law:
Then follow the reforms that President Miley will present on national television next Tuesday night: a national commitment to fiscal and monetary stability, modernizing the labor market and reforming the country’s penal code.
Finally, the agenda includes a project to adapt the minimum budget system to preserve glaciers and the glacier environment.
Extraordinary sessions will be called from next Wednesday, December 10, to Wednesday, December 31. Its duration will be four weeks, with a total of 13 working days.
It is clear that the aforementioned tax reform will not be part of the extraordinary sessions that will be held until December 31, 2025.
So, what tax changes are you looking to approve before the end of the year? The answer is simple. These are the ones contemplated in the Tax Innocence Project and the changes proposed at the end of the Labor Modernization Project that will become official next Tuesday.
Tax Innocence Project
The draft law on the “Principle of Financial Innocence” includes a Comprehensive reform of the criminal tax systemwhich sets significant changes in the amounts at which conduct is considered criminal, in addition to establishing Alternative mechanisms to criminal proceedings to encourage collection.
The initiative proposes a Deep update of monetary thresholds For tax and social security crimes, and some Multiplied by one hundred Regarding current values. It also proposes a new scheme for the extinction of criminal action, with potential Pay off the debt and an additional 50% even after filing a formal complaint.
Major changes in the criminal tax system
The project is proposed Increase minimum amounts significantly Which constitute tax crimes, both at the general level and in relation to social security. Below are details of the new standards:
Tax crimes
- Simple evasion: Ranges from $1,500,000 to $100,000,000 per tax and fiscal year.
- Extreme evasion: From $15,000,000 to $1,000,000,000.
- Fraudulent use of tax benefits (exemptions, deductions, etc.): From $2,000,000 to $200,000,000.
- Use of fabricated invoices or documents: From $1,500,000 to $100,000,000.
- Improper use of tax benefits: From $1,500,000 to $100,000,000.
Crimes related to social security
- Simple evasion: From $200,000 to $7,000,000.
- Extreme evasion: From $1,000,000 to $35,000,000.
- Embezzlement of social security resources: From $100,000 to $3,500,000.
Other common crimes
This update contains Direct impact on criminal tax litigationBecause it significantly reduces the number of cases that can be prosecuted under current legislation.
A new standard for expiring a criminal case
Currently, the system allows – Extinguishing the criminal case by paying the debt and its interest Only once, and before reporting. New project Expand that interestallowing even extinction After filing a criminal complaintas long as the taxpayers Pay the total amount due, interest and an additional 50%.
This amendment aims to prevent the abusive use of mechanisms such as Comprehensive repair stipulated in the Penal Code, and in reality it is a custom Delay operations Without ensuring an effective state response. next to, Expressly prohibited Application of this method in the criminal tax system.
Changes to ARCA’s Whistleblowing Policy
They join Two new assumptions It has the tax authority You do not have to file a criminal complaintWithout the need for a legal opinion:
- When the taxpayer Justified technical or accounting standards Used to settle tax.
- when Submit original or corrected affidavits under oath Before you are notified of the inspection.
These cases are in addition to the two currently expected cases in which a prior opinion is required. The idea is that if the taxpayer You acted in good faithCriminal proceedings are unnecessary, and the priority is to recover the money owed.
Redrafting fines and formal violations
The project is also proposed Robust modernization of sanctions for official violations. Some examples of the new scale:
- to $200-$400 to $220,000-$440,000
- to $5,000 – $10,000 to $5,000,000 – $10,000,000
- to $80,000 – $200,000 to $6,000,000 – $15,000,000
- to $500 – $45,000 to $500,000 – $35,000,000
- Fixed quantity of $10,000,000 becomes $10,000,000,000
that it Inflationary adjustmentbut which also has a purpose Re-evaluating the deterrent effect of fines.
Reduce prescription durations
Two relevant changes have been proposed:
- From 5 to 3 years In tax matters for registered and compliant taxpayers.
- From 10 to 5 years In Social Security for those who submit their returns on time.
With this one seeks Positively differentiate compliant taxpayersand reduce the periods that the Treasury can use for retrospective investigation.
New simplified income tax system
One of the most notable innovations in the project is the creation of… Simplified earnings system For resident persons and undivided estates. This scheme targets taxpayers who… They do not qualify as senior taxpayers And they have:
- Income up to 1 billion dollars
- Legacy up to 10 billion dollars
ARCA will suggest a Pre-filled declarationbased on the available information. The taxpayer may accept it, complete it, or correct it. If you accept this and pay on time, the tax will be released The financial period may not be reopened except in the following cases:
- Use Fabricated invoices
- Improper discounts
- Deleted income
Accuracy assumption and “tax ceiling”
The law stipulates this Assume honesty of sworn statements submitted under this system, which limits the Treasury’s ability to initiate audits at announced intervals, unless verified. Big contradictions.
next to, The use of unjustified capital increases as an automatic incentive for inspection is deactivated. This measure seeks to protect taxpayers who comply with the system, and at the same time Avoid interpretive violations By the collection agency.
Protecting compliant taxpayers
If the taxpayer adheres to the simplified system and then moves to another system, The protection and editing effect will be maintained Of the statements made. The inspection may only be expanded if relevant discrepancies are discovered, without affecting the periods specified or covered by the “financial ceiling” related to money laundering or the new regime.
Repair work
Changes in profits, VAT and internal taxes
Value added tax
With regard to value-added tax, the labor reform project in subsection (m) of paragraph four of Article (28) of the value-added tax law includes the following:
“M) Electrical energy used in irrigation systems and/or equipment in the agricultural industry sector.”
income tax
With regard to profits, the eleventh paragraph of Article (25) of the Income Tax Law shall be replaced with the following text:
“Losses resulting in fiscal years beginning on or after January 1, 2025, Including, it will be updated taking into account the difference in the general consumer price index (CPI) provided by the National Institute of Statistics and Census, a decentralized body operating within the scope of the Ministry of Economy, operating between the closing month of the fiscal year in which it arose and the closing month of the fiscal year in which it was settled, without applying the provisions of the first paragraph of Article 93 of this law.
Moreover, it has been proven:
Subsection n) of Article 26 of the Income Tax Law shall be replaced by the following:
“n) Profits generated from renting real estate for residential use and the rental value of the residential dwelling.
Likewise, the result derived from INA is also exempt.Sale of real estate and transfer of real estate rights covered by the provisions of Article 99 of this law and which are sold or transferred as of January 1, 2026, This is in the manner specified by the regulations in this regard.”
Replace the last paragraph of Subsection U) of Article 26 of the Income Tax Law with the following:
“In the case of values covered by the provisions of Article 98 of the law, with the exception of digital currencies, the subjects covered by that article are also exempt from the consequences of purchasing, exchanging, trading, or disposing of them, whether they are listed on stock exchanges or markets authorized by the Securities Commission or not, without applying the provisions of Article 109 of the Tax Law.”
Joined, with effects to Fiscal years beginning on or after January 1, 2026, As an unnumbered article, Article 58 of the Income Tax Law follows the text issued by the 2019 Order and its amendments as follows:
“Article…- Owners of wintering and/or fattening establishments referred to in point 2 of subsection d) of the first paragraph of Article 56 of this Law may choose to value their stocks by the methods described in subsections a) or b) of Article 57 of this Legal Standard, depending on the type of farm in question. To calculate the valuation of “calves” and “heifers”, taxpayers may use the relationship indicators given in the tables appended to Law No. 23.079, for all “calves” corresponding to “cow from One to two years” and for all “calves” that correspond to “calves from one to two years”, depending on the variety in question.
The table ratios of subsection (a) of Section 73 of the Income Tax Law of 2019, as amended, are amended for fiscal years beginning on or after January 1, 2026, inclusive, as follows:
a) Where you say “30%” it should become “27%”,
b) Where it says “35%” it should be “31.5%”.
Internal taxes
Finally, the labor reform project abolishes the tax stipulated in the Internal Tax Law on: insurance, cellular and satellite phone services, luxury goods and property. Cars and enginesRecreational or sports boats and aircraft.