Fiscal Innocence: Government Expands Asset Regularization and Eliminates Wealth and Income Caps

The Ministry of Economy announced changes to the Fiscal Innocence Bill, which will be sent to Congress. The initiative modifies the previously approved regime and seeks to expand the universe of taxpayers who can regularize their savings without penalties. The changes include the elimination of income and wealth caps, a new threshold so that ARCA cannot break the presumption of accuracy, and deadlines for corrections and refunds.

What changes in the asset regularization regime

According to the Ministry of Economy, the bill eliminates the conditions that currently limit access to the simplified regime. Today, to join, the taxpayer must simultaneously meet three requirements: annual income not exceeding one billion pesos, total wealth not exceeding ten billion pesos, and not being classified as a Large Taxpayer. The new wording eliminates these limits: all resident individuals and undivided estates can join, regardless of wealth or income. The only caveat is that Large Taxpayers can use the simplified modality but will not enjoy the presumptions or the liberating effects.

The threshold so that ARCA cannot break the presumption

Another central change touches the most sensitive point: when the tax authority can break the taxpayer’s presumption of accuracy. The current law establishes that if ARCA’s challenge results in an increase of 15% or more over what was declared, the presumption automatically falls. The bill introduces a minimum threshold: even if the 15% is exceeded, the presumption is not broken if the nominal difference claimed does not reach the equivalent of 5% of the evasion amount provided for in the Criminal Tax Law. In concrete numbers, if the difference does not exceed five million pesos, the presumption is maintained.

Deadlines for corrections and refunds

The bill also establishes that if ARCA detects a significant discrepancy, the taxpayer may file a corrective tax return and pay the difference plus interest within up to 15 business days from notification of the official determination. In addition, if the taxpayer challenges and wins, the presumption of accuracy is fully restored, and ARCA must refund the contributions paid with interest within no more than 45 business days from notification of the final resolution.

Comparison between the current law and the bill

To gauge the scope of the changes, the key points between the current regulations and the announced bill are compared.

Methodological note: the comparison was prepared with data published by the Ministry of Economy in its official statement of October 16, 2025. Values are expressed in Argentine pesos as reported by the source. No conversions to other currencies were made.

What to watch next

The key point to follow is the fine print of the bill when it enters Congress, particularly how the five million peso threshold will be regulated and whether the exclusion of benefits for Large Taxpayers is maintained. It will also be relevant to see if the opposition introduces changes during the parliamentary debate, since the ruling party does not have a majority in either chamber.