The Ministry of Economy presented this Wednesday a series of modifications to the Tax Amnesty bill, with the aim of expanding the scope of the regime and providing greater guarantees to taxpayers. The changes were announced by Minister Luis Caputo and the Legal and Technical Secretary of the Presidency, María Ibarzabal Murphy, in a press conference.
What the original bill established and what changes
The original bill, which had already been approved, established that only those taxpayers who simultaneously met three conditions could adhere to the regime: annual income not exceeding one billion pesos, total assets not exceeding ten billion pesos, and not being considered a ‘Large Taxpayer’ according to ARCA regulations.
The new initiative eliminates those caps, allowing all resident individuals and undivided estates in the country to enter, without distinction of assets or income. However, a caveat remains for ‘Large Taxpayers’: they may adhere to the simplified modality, but will not enjoy the presumptions, liberating effects, or other benefits provided by law.
Minister Caputo explained that the decision to promote a new law arose after receiving observations from tax advisors on various aspects of the previously approved regulations. ‘As the weeks and months went by, we gathered this information. We set up a working group with tax experts with the aim of clarifying some issues that make citizens feel much more at ease,’ he said.
The four central changes
In addition to the elimination of caps, the bill introduces modifications in four key points:
- Covered subjects: income and asset limits are eliminated, and it is clarified that ‘Large Taxpayers’ can adhere but without full benefits.
- Breaking the presumption of accuracy: currently, if ARCA challenges and the increase exceeds 15% of what was declared, the presumption automatically falls. The new bill establishes a minimum threshold: even if the 15% is exceeded, the presumption is maintained if the nominal difference does not reach five million pesos.
- Deadline to rectify: if ARCA detects a significant discrepancy, the taxpayer may submit a corrective sworn declaration and pay the difference (plus interest) within up to 15 business days from notification of the official determination.
- Restoration of the presumption and refund: if the taxpayer pays and then the resolution is favorable, the presumption of accuracy is fully restored and ARCA must refund the contributions paid with interest within no more than 45 business days.
Context: informality and savings outside the system
Caputo stressed that the initiative seeks to respond to a process of growing informality generated by years of high tax pressure, fiscal deficit, monetary issuance, inflation, and exchange restrictions. He noted that these factors led many Argentines to keep their savings outside the financial system.
According to the minister, currently dollar deposits in the financial system are at record levels close to 40 billion dollars, but there is an amount more than four times that figure in savings kept outside the banking circuit. ‘For individuals, keeping dollars under the mattress is a very bad business,’ he said.
Documents and open questions
| Document | What it establishes | What it does not establish | Open questions |
|---|---|---|---|
| Original bill (approved) | Conditions to adhere: income ≤ $1,000,000,000, assets ≤ $10,000,000,000, not being a Large Taxpayer. Breaking of presumption if increase ≥15%. | It does not define a minimum threshold in pesos for the break. It does not contemplate rectification with deadlines. | What was the exact amount of the difference that could cause the break in specific cases? |
| Modified bill (announced) | Eliminates income and asset caps. Large Taxpayers can adhere without full benefits. Minimum threshold of $5,000,000 to not break presumption. 15-day deadline to rectify. Refund in 45 days. | It does not detail the full text of the articles. It does not specify how the 5% of the evasion amount will be calculated. It does not clarify if the changes apply retroactively. | What is the exact wording of the modified articles? How will the threshold be implemented in practice? |
Value module: scope comparison
To gauge the change, one can compare the scope of the original regime with the modified one in terms of covered subjects.
- Document: Original bill and announcement of modifications.
- Agency and date: Ministry of Economy, August 14, 2025 (date of the conference).
- Unit: Eligible taxpayers.
- Values used: Original: only those with income ≤ $1,000,000,000 and assets ≤ $10,000,000,000. Modified: all resident individuals and undivided estates.
- Operation: An exact percentage cannot be calculated without taxpayer distribution data, but a significant expansion is inferred.
No currency conversion is performed because the amounts are expressed in Argentine pesos and no official exchange rate is available in the material.
What to follow
The modified bill must be sent to Congress for consideration. It is relevant to follow the final wording of the articles, especially the definition of the five million peso threshold and how it will apply to Large Taxpayers. It will also be key to observe the reaction of tax experts and whether the modifications effectively increase adherence to the regime.
Fuentes consultadas
- REALPOLITIK
- Argentina.gob.ar Fuente primaria
- Crónica
El Sereno contrastó las fuentes enlazadas y añadió contexto, comparación o análisis documental. Las fuentes primarias están identificadas. La nota no se presenta como investigación de campo ni como entrevista propia, salvo indicación expresa.
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