Introduction
On May 26, 2026, through Resolution 801/2026 (RESOL-2026-801-APN-MEC), the Ministry of Economy approved the application by Minera San Jorge S.A. (MSJSA) to join the Large Investment Incentive Regime (RIGI, by its Spanish acronym) for the “PSJ Cobre Mendocino” project. This is one of the first mining sector projects to obtain approval under the regime created by Law 27,742, the first involving copper mining in the province of Mendoza, and one of the largest productive projects approved to date in the country.
Canosa Abogados assisted MSJSA throughout the entire legal structuring and accession process, in collaboration with ASAP Consultores on accounting, tax, and mining administrative matters.
The Applicable Regulatory Framework
Law 27,742 established, under Title VII, the RIGI, designed to grant tax, customs, and foreign exchange incentives to “Unique Projects” meeting the requirements set forth by the law and its regulations, with the aim of generating predictability, stability, and competitiveness to attract Large Investments in strategic sectors.
Decree 749/2024 regulated Title VII, designating the Ministry of Economy as the Enforcement Authority and providing for a Project Evaluation Committee. Resolution 814/2024 constituted said Committee and designated the Secretariat for Energy and Mining Coordination as the RIGI Coordination Unit, while Resolution 1074/2024 approved the regime’s specific procedures.
For mining projects falling under the subsector “First and second category minerals under the National Mining Code (excluding potassium and lithium)” — item (iv) of subparagraph n of Article 3 of the Annex to Decree 749/2024 — the regime requires a minimum investment amount, a reasonable construction timeline, a minimum threshold for local supplier participation, and proof of technical, economic, and financial feasibility.
The “PSJ Cobre Mendocino” Project
The Project is dedicated to the prospecting, exploration, and mining development of copper in the Mendoza foothills (precordillera), at elevations between 2,400 and 2,600 meters above sea level, in the Uspallata district, Las Heras department, Province of Mendoza. It contemplates the construction and operation of an open-pit mine and a concentrating plant based on conventional flotation, with an estimated capacity of 40,000 metric tons of fine copper per year. The main approved parameters are:
- Total committed investment in eligible assets for the construction phase: USD 613,430,234.
- Two-year investment: USD 188,598,566, exceeding 40% of the minimum amount required by Articles 172 and 173 of Law 27,742.
- Construction start: June 2027. Operations start: January 2029.
- Deadline for minimum investment: September 1, 2028 (Art. 176, Law 27,742).
- RIGI accession date: May 13, 2026, as of which rights are vested pursuant to Art. 177.
- Local suppliers: 27% of the amount allocated to suppliers, goods, and infrastructure works, exceeding the 20% floor under subparagraph l of Art. 47 of the Annex to Decree 749/2024.
MSJSA was incorporated as a Unique Project Vehicle (UPV) in the form of a corporation (sociedad anónima), adapting its corporate purpose exclusively to activities related to the Project (Art. 169, Law 27,742), and agreed to submit any disputes to the mechanisms set forth in Art. 221 of the law, including the RIGI Panel (Art. 134 of the Annex to Decree 749/2024).
Canosa Abogados’ Advisory Role
Obtaining RIGI accession requires highly complex legal and economic structuring: every requirement set forth by the law and its regulations must be substantiated with technical documentation and solid formal declarations, within a demanding timeline and with the involvement of multiple government agencies.
Canosa Abogados led the comprehensive legal advisory for the project, covering — among other matters — the structuring of the UPV and the adaptation of MSJSA’s corporate purpose; the preparation and filing of the accession application and investment plan; the construction schedule and local supplier development plan (subparagraphs f and l of Art. 47 of the Annex to Decree 749/2024); the declarations on technical, economic, and financial feasibility, the risk matrix, and the mitigation plan; coordination with the independent financial-economic evaluator; liaison with the Mining Secretariat, the RIGI Coordination Unit, the Evaluation Committee, and the Central Bank of the Argentine Republic (BCRA); and the design of the dispute resolution framework under Art. 221, including the RIGI Panel.
The firm worked in collaboration with ASAP Consultores, a Mendoza-based consultancy specializing in the mining sector, which assisted the client on accounting, tax, and mining administrative matters. ASAP was represented by María Laura Gil and Ana Gil Barbera.
The file was recommended for approval by the RIGI Project Evaluation Committee through Record No. 19 of May 14, 2026, which led to the issuance of Resolution 801/2026.
Implications and Final Remarks
The approval of the “PSJ Cobre Mendocino” Project carries particular significance. It consolidates the RIGI as an effective tool for channeling large-scale investments in strategic sectors, in a context where regulatory predictability and the stability of incentives are decisive for long-term decision-making. It also positions the Province of Mendoza as a destination for significant copper investment — a mineral whose global demand is projected to rise due to its key role in the energy transition. And it provides a benchmark case for the integrated operation of the regime, with the articulation between the UPV, the Enforcement Authority, the Mining Secretariat, the Evaluation Committee, and the BCRA in accordance with the procedures of Resolution 1074/2024.
The simultaneous fulfillment of the investment thresholds, local integration requirements, and the reasonableness of the construction timeline demonstrates that the RIGI demands robust technical and legal preparation, in which the role of legal counsel is decisive.
At Canosa Abogados, we remain committed to supporting investors and operators in large-scale projects under the RIGI and Argentine promotional regimes. The approval of the “PSJ Cobre Mendocino” Project represents a significant precedent for the Argentine mining sector and a source of great pride for our team.
