On 9 October 2026, the Argentine Official Gazette published Law 27826, which introduces significant amendments to the Tax Criminal Regime (Régimen Penal Tributario) and the Tax Procedure Law (Ley de Procedimiento Tributario). The legislative update aims to modernize enforcement tools, align sanctions with current economic realities, and strengthen the procedural framework for tax assessments and appeals. The law enters into force on the day following its publication, with certain procedural provisions applicable to ongoing administrative and judicial proceedings. The reform was driven by the Ministry of Economy and the Federal Administration of Public Revenue (AFIP), now reorganized as the Agency for Revenue and Customs Control (ARCA), to close loopholes and enhance voluntary compliance.
Key Takeaways
- Expanded Criminal Offenses and Higher Penalties: The amendment broadens the definition of tax evasion to include systematic omission of filing obligations and the use of falsified digital certificates. Maximum prison sentences are increased from six to eight years, and fines are now calculated as a multiple of the omitted tax amount, adjusted quarterly by the Consumer Price Index.
- Streamlined Administrative Procedure: The Tax Procedure Law now mandates electronic notifications as the default channel, reduces the term for taxpayers to present defenses from 15 to 10 business days, and introduces a fast-track resolution for low-value disputes (under ARS 5 million). Interest on tax debts will accrue at the Central Bank’s monetary policy rate plus a 3% spread, replacing the previous fixed statutory rate.
- Enhanced International Cooperation: The law incorporates provisions for automatic exchange of information under OECD CRS and BEPS frameworks, granting ARCA direct access to foreign bank account data without prior judicial order when a tax treaty permits. This facilitates cross-border audits and strengthens the fight against base erosion and 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