On December 26, 2025, the Senate of the Argentine Nation approved the “Fiscal Innocence Law” (the “Law”), which introduces amendments to the Tax Criminal Regime (Law No. 24,769), the Tax Procedures Law (Law No. 11,683), and the Argentine Civil and Commercial Code (hereinafter, the “Code”), and also creates a Simplified Sworn Statement Regime, with the aim of redefining the criminal and administrative treatment of tax infringements.
With respect to the amendments introduced to the Code, the Law eliminates the authority of local legislatures to regulate limitation periods (statute of limitations) in tax matters, establishing for all jurisdictions the limitation periods provided for under the Tax Procedures Law, thereby unifying such periods throughout the Republic.
In addition, the Law amends other tax procedure regulations, among which the following stand out: the reduction of the limitation period for judicial collection of social security contributions from five (5) to three (3) years, and from ten (10) to five (5) years for health insurance contributions, in cases where taxpayers have timely complied with the filing and payment of the tax, provided that the tax return is not challenged due to a significant discrepancy.
The Law defines a significant discrepancy as a difference exceeding fifteen percent (15%) or ARS 100,000,000 between the amount declared by the taxpayer and the adjustment assessed by the tax authority.
The provisions of the Law entered into force on January 2, 2026.
