As of 7 October 2026, the Argentine National Congress has sanctioned Law 27.950, denominated “Régimen de Inocencia Fiscal II” (Fiscal Clemency II), yet the Executive Branch has not promulgated the statute, leaving its entry into force uncertain. The bill, passed by the Senate on 3 October, replicates the 2024 amnesty framework but introduces critical modifications: it extends the voluntary disclosure window to 180 days post-promulgation, reduces the special tax rate on undeclared assets from 15% to 10% for holdings repatriated within 90 days, and explicitly excludes crypto-assets from the “blanqueo” unless held through locally licensed custodians. With the annual Personal Assets Tax (Impuesto sobre los Bienes Personales) and Income Tax (Impuesto a las Ganancias) sworn declarations due 13 October 2026, practitioners face a strategic dilemma: file under current law assuming the amnesty will not apply retroactively, or delay submission risking late-filing penalties. The AFIP has issued an informal note indicating it will accept amended returns within 30 days of promulgation without interest.
Key Takeaways
- Legislative Limbo: The law lacks legal effect until promulgated and published in the Official Gazette; no formal deadline binds the President to act.
- Repatriation Incentive: The 10% special rate applies only to funds entering the Argentine financial system via authorized entities within the first 90 days of the regime’s effectiveness.
- Filing Strategy: Advisors should prepare dual-scenario workpapers — one assuming standard 2025 fiscal year treatment, another incorporating amnesty benefits — to enable rapid amendment once promulgation occurs.
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