Effective 1 October 2026, Decree 789/2026 formally launched the Régimen de Incentivo a la Minería e Inversiones (RIMI), a companion framework to the existing Régimen de Incentivo para Grandes Inversiones (RIGI) established under Law 27.742. While RIGI targets projects exceeding USD 200 million with 30-year fiscal stability, VAT acceleration, and customs duty exemptions, RIMI extends a tailored package to small and medium enterprises (SMEs) operating in the Vaca Muerta shale basin with investment commitments between USD 5 million and USD 50 million. Key RIMI benefits include: immediate VAT credit refund on capital goods (vs. standard 6-month wait), a 10-year Income Tax rate reduction from 35% to 25%, accelerated depreciation over 3 years for drilling equipment, and exemption from the Check Tax (Impuesto a los Créditos y Débitos) on project-related banking transactions. Eligibility requires certification as a “PyME Vaca Muerta” by the Energy Secretariat, local content minimums of 40%, and adherence to environmental performance bonds.
Key Takeaways
- Dual-Regime Access: SMEs can now combine RIMI benefits with provincial investment promotion regimes (e.g., Neuquén Law 3.120) without clawback provisions, creating stacked incentive structures.
- Application Window: The Energy Secretariat will accept RIMI enrollment applications until 31 March 2027; approved projects must commence construction within 12 months of certification.
- Transfer Pricing Safeguard: RIMI participants must file annual Country-by-Country Reports (CbCR) aligned with BEPS Action 13, even if below the EUR 750 million threshold, to prevent profit shifting.
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.
Source: Read Official Announcement