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, and also creates a Simplified Sworn Statement Regime, with the aim of redefining the criminal and administrative treatment of tax infringements.
Among the reforms introduced by the Law, the following may be highlighted:
- The updating of the economic thresholds that constitute the objective condition of punishability for the configuration of the different offenses of tax evasion provided for under the Tax Criminal Regime, as well as the expansion of the grounds for extinguishing criminal action.
- The increase in the amounts of fines applicable to failures to file tax returns and to violations of laws and decrees of mandatory compliance in tax matters, as provided for under the Tax Procedures Law.
- The amendment of tax statute of limitations periods established under the Argentine Civil and Commercial Code and other applicable regulations.
The Law entered into force on January 2, 2026.
