The executive has already made the decree official by calling for extraordinary meetings from December 10th to 31st. The agenda consists of six initiatives, starting with the 2026 draft budget and ending with the reforms announced by Javier Milei.
The first item that the national government wants to adopt is the 2026 budget. The second item on the agenda of the extraordinary sessions is the tax innocence bill:
Then follow the reforms that President Milei will unveil on national television next Tuesday evening: the national commitment to fiscal and monetary stability, the modernization of the labor market and the reform of the national penal code.
Finally, the project to adjust the minimum budget for the preservation of glaciers and the periglacial environment is on the agenda.
The extraordinary meetings will be convened from next Wednesday, December 10th to Wednesday, December 31st. They will take four weeks with a total of 13 business days.
What is clear is that the tax reform mentioned above will not be part of the extraordinary meetings that will take place until December 31, 2025.
So what tax changes do you want to approve before the end of the year? The answer is simple. They are those considered in the tax innocence project and the proposed changes at the end of the work modernization project, which will be officially announced next Tuesday.
Tax Innocence Project
The draft law on the “principle of tax innocence” includes a Comprehensive reform of the punitive tax systemwhich, in addition to creating significant changes in the amounts above which behavior is considered criminal alternative mechanisms to criminal proceedings to promote confiscation.
The initiative proposes a comprehensive update of monetary thresholds for tax and social crimes, some of them are multiplied by one hundred in relation to current values. A new system for the abolition of criminal acts is also proposed, with the possibility of doing so pay off the debt and another 50%, even after a formal complaint.
Important changes in the penalty tax system
The project proposes significantly increase the minimum amounts which constitute tax crimes, both at a general level and in relation to social security. Below is a detail of the new scales:
Tax crimes
- Easy dodge: increases from $1,500,000 to $100,000,000 per tax year and fiscal year.
- Aggravated 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 invoices or apocryphal documents: from $1,500,000 to $100,000,000.
- Impermissible use of tax benefits: from $1,500,000 to $100,000,000.
Crimes related to social security
- Easy dodge: from $200,000 to $7,000,000.
- Aggravated evasion: from $1,000,000 to $35,000,000.
- Misappropriation of social funds: from $100,000 to $3,500,000.
Other common crimes
This update has one direct impact on criminal tax proceedingsas it significantly reduces the number of cases that could be prosecuted under current law.
New criterion for preventing criminal acts
Currently the regime allows end the crime by paying the debt and interest only once and before reporting. The new project extend this advantagewhich even makes extinction possible after filing the criminal complaintas long as the taxpayer Pay the entire amount due, interest and an additional 50%..
The aim of this change is to prevent the improper use of mechanisms such as: comprehensive repair provided for in the Criminal Code, which is usually the case in reality delay the processes without ensuring effective reimbursement to the state. Aside from that, is expressly prohibited the application of this route in the punitive tax system.
Changes to ARCA’s Whistleblowing Policy
They join in two new assumptions in which the tax authority You should not press chargeswithout the need for a legal opinion:
- If the taxpayer has well-founded technical or accounting criteria used to pay the tax.
- When Submit original or corrective affidavits before you are notified of an inspection.
These cases are in addition to the two cases currently envisaged where a prior opinion is required. The idea is that if the taxpayer acted in good faiththe criminal proceedings are unnecessary and collecting the money owed takes priority.
Reformulation of fines and formal violations
The project also suggests a strong update of the sanctions for formal violations. Some examples of the new scale:
- From $200-400 to $220,000-440,000
- From $5,000-$10,000 to $5,000,000-$10,000,000
- From $80,000-$200,000 to $6,000,000-$15,000,000
- From $500-$45,000 to $500,000-$35,000,000
- The fixed amount of $10,000,000 becomes $10,000,000,000
It is a Inflation adjustmentbut that also has the purpose Reassess the deterrent effect of fines.
Shortening of prescription times
Two relevant changes are proposed:
- From 5 to 3 years in tax matters for registered and paying taxpayers.
- From 10 to 5 years in social security for those who submit their returns on time.
This is how you search positively differentiate the compliant taxpayerand shorten the time periods that the Treasury Department can use for retroactive investigations.
New simplified income tax system
One of the project’s most notable innovations is the creation of a Simplified earning system for human persons and resident undivided goods. This regulation is aimed at taxpayers who: They are not considered big taxpayers and that she:
- Income up to 1 billion dollars
- Inheritance of up to 10 billion dollars
ARCA will suggest a pre-filled affidavitbased on the information available. The taxpayer can accept, supplement or correct it. If accepted and paid on time, the tax will be released and the fiscal period may not reopen except in the following cases:
- Use of apocryphal calculations
- Impermissible deductions
- Lost income
Presumption of correctness and “tax cap”
This is what the law provides assume truthfulness of affidavits submitted under this regime, thereby limiting the ability of the Treasury to initiate audits for the specified periods unless they are verified significant deviations.
Aside from that, The use of unjustified capital increases as an automatic trigger for the audit will be deactivated. The aim of this measure is to simultaneously protect taxpayers who comply with the regulation Avoid misinterpretation through the debt collection agency.
Protecting the Compliant Taxpayer
In the event that the taxpayer complies with the simplified regime and then switches to another regime, Protection and liberating effects are retained of the statements made. Control may only be extended if relevant discrepancies are identified, without affecting any prescribed timelines or the scope of the money laundering “fiscal cap” or the new regime.
Labor reform
Changes in profits, VAT and internal taxes
VAT
Regarding VAT, the labor reform project includes, as subsection m) of the fourth paragraph of Article 28 of the VAT Law, the following:
“m) Electrical energy used for irrigation systems and/or equipment for the agro-industrial sector.”
Income tax
With regard to profits, paragraph 11 of Article 25 of the Income Tax Law is replaced by the following:
“Losses arising in fiscal years beginning on or after January 1, 2025, They are updated, among other things, taking into account the fluctuations in the general consumer price index (CPI) provided by the NATIONAL INSTITUTE OF STATISTICS AND CENSUS, a devolved body within the MINISTRY OF THE ECONOMY, which operates between the final month of the financial year in which they were created and the final month of the financial year in which they are accounted for, without the provisions of the first paragraph of Article 93 of this Law being applicable.
In addition, it is noted:
Article 26(n) of the Income Tax Law is replaced by the following:
“n) Profits from the rental of real estate for residential purposes and the rental value of the dormitory.
The result derived from the ena is also excluded.Sale of real estate and transfer of rights to real estate within the meaning of Article 99 of this Law, sold or transferred from January 1, 2026, in the conditions laid down in this regard by the Regulation.”
Replace the last paragraph of Article 26, subsection u) of the Income Tax Law with the following:
“In the case of values falling under the provisions of Article 98 of the Law, with the exception of digital currencies, the subjects referred to in this article are also exempt from tax for the results of their purchase, exchange, exchange or disposal, whether or not they are listed on stock exchanges or markets approved by the National Securities Commission, without the provisions of Article 109 of the Tax Law being applicable.”
Join to make an impact Fiscal years beginning on or after January 1, 2026, As an unnumbered article subsequent to Article 58 of the Income Tax Law, text arranged in 2019 and its amendments, the following:
“Article… – The owners of the wintering and/or fattening farms referred to in Article 56, paragraph 1, subsection d) number 2 of this Law may choose to value their stocks according to the methods described in Article 57, subsection a) or b) of this legal norm, depending on the type of farm in question. To calculate the valuation of the “heifers” and “oxen”, taxpayers may use the relationship indices contained in the tables attached to the Law No. 23,079, for all “heifers” that corresponds to “heifers aged one to two years”, and for all “steers” that corresponds to “steers aged one to two years”, depending on the category.
The rates of the tariff table of Article 73 subsection a) of the Income Tax Law up to 2019 and its amendments are changed for financial years beginning on or after January 1, 2026 as follows:
a) Where it says “30%” it should read “27%”.
b) Where it says “35%” it should read “31.5%”.
Internal taxes
Finally, the labor reform project repeals the tax on insurance, mobile phone and satellite phone services, luxury items, etc. provided for in the internal tax law Motor vehicles and enginesPleasure or sports boats and airplanes.
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