ARGENTINA: INCOME TAX SIMPLIFIED TAX RETURN REGIME REGULATIONS.
Argentina | Simplified Income Tax Return Regime – Final Regulatory Framework
Argentina has now fully published the regulatory framework for the Simplified Income Tax Return Regime introduced by Law No. 27,799, through the issuance of Decree No. 93/2026 and General Resolution No. 5820/2026.
Together, these rules define who may access the regime, how eligibility is verified, how simplified returns are filed, and—critically—the scope and limits of audit protection.
🔍 Scope and Eligibility
The regime applies to resident individuals and undivided estates that:
▪️ Meet defined income and net worth thresholds, and
▪️ Are not classified as Large National Taxpayers, assessed as of December 31st of the prior year and over the two preceding fiscal years.
Tax residency must be verified at the time of election and throughout continued participation.
📑 Enrollment, Validation, and Filing Mechanics
▪️ Applicable to fiscal years starting January 1st, 2025, onwards.
▪️ Enrollment, annual ratification, validation of prior elections, withdrawal, and exclusion are carried out through the Federal Tax and Customs Authorities (ARCA)’s digital platform.
▪️ The ARCA issues a digital certificate of enrollment, which constitutes legal proof of inclusion and may be relied upon by third parties.
▪️ Income tax returns are pre-filled by the ARCA, based exclusively on:
- Gross income (Argentine and foreign source), and
- Allowable deductions under Income Tax Law.
▪️ Taxpayers may review, amend, confirm, and submit the tax return, and are relieved from certain reporting obligations under the general regime
🛡️ Core Benefit — with Strict Conditions
Where the simplified tax return is properly filed and paid on time (or covered by a payment plan), the taxpayer benefits from:
▪️ A payment release effect for the relevant fiscal year (“base year”), and
▪️ A presumption of accuracy extending to non-statute-barred Income Tax and VAT periods, including years with no filing obligation.
This materially limits audit exposure — unless the protection is lifted.
⚠️ Loss of Protection: “Significant Discrepancy”
Under Decree No. 93/2026, ARCA may challenge the simplified return where it detects:
▪️ Adjustments of 15% or more,
▪️ Differences exceeding criminal tax thresholds, or
▪️ Use of false or sham documentation, regardless of amount.
In such cases, the simplified tax return may be impugned, the payment release effect and presumption of accuracy are lost, audits may be extended to prior non-prescribed years, and penalties or criminal exposure may arise. Importantly, the burden of proof lies with the Tax Authorities, based solely on declared data and third-party information.
🔄 Financial Formalization & Safe Harbors
▪️ Transactions must flow through the formal financial system; cash payments are excluded.
▪️ Voluntary amended returns filed before audit notification, or early correction of irregular documentation before formal assessment, do not constitute a significant discrepancy.
📌 Mandatory validation under General Resolution No. 5820/2026
Taxpayers who opted into the simplified regime under Decree No. 353/2025 must formally validate their election to remain covered. Failure to do so results in automatic reversion to the general income tax regime.
📅 Effective date: February 8th, 2026📍 System availability: February 11, 2026
👉 Key Takeaway
Argentina’s simplified regime delivers meaningful compliance certainty and audit protection, but only for taxpayers who actively manage eligibility, validation, financial traceability and ongoing compliance.
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