On 6 October 2026, the Ministry of Economy submitted Bill 4.892/2026 to Congress, proposing a comprehensive overhaul of the Capital Markets Law (Law 26.831) to enhance SME access to financing through securitization and collateral innovation. The draft legislation introduces three tax-relevant mechanisms: (1) a new “Warrant Electrónico” regime allowing digital warehouse receipts to serve as negotiable securities with VAT suspension on underlying goods until final sale; (2) expanded “Prenda Registrada” (registered pledge) over movable assets, including future receivables and intellectual property, with Stamp Tax (Impuesto de Sellos) exemption for SME borrowers; and (3) a simplified “Pagaré Bursátil” (market promissory note) issuance process eliminating CNV pre-approval for offerings under ARS 500 million, subject to a 5% withholding tax on interest paid to non-residents — down from the current 15.5%. The bill also mandates electronic invoicing (Factura de Crédito Electrónica MiPyME) integration for all supply-chain financing transactions, enabling real-time VAT credit tracking.
Key Takeaways
- VAT Deferral on Inventory: Electronic warrants permit VAT payment deferral until the secured goods are sold, improving working capital for agro-export SMEs holding grain or livestock.
- Stamp Tax Relief: Registered pledges for SMEs are exempt from provincial Stamp Tax (typically 0.5%-1.2% of secured amount), reducing upfront financing costs by an estimated 8-12%.
- Withholding Rate Cut: The reduced 5% non-resident interest withholding aims to attract foreign private credit funds; however, treaty benefits (e.g., Argentina-Spain DTT 12% cap) still apply where more favorable.
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