Argentina

Argentina implements selected tax amendments and reduces certain consumption taxes

Argentina enacted a package of tax measures that introduces targeted VAT and Income Tax amendments (with several changes effective in 2025–2026), and provides tax burden relief by eliminating certain selective consumption (excise-type) taxes as from the month following the law’s entry into force. The package also creates an Incentive Regime for Medium-Sized Investments (RIMI) for MSMEs, although the most broadly relevant changes for large multinational groups may consist of the general VAT/income tax amendments and the excise tax repeal.

Value Added Tax (VAT)

Electricity used in irrigation systems (agro-industrial sector)

Effective as of the first day of the month immediately following the law’s entry into force, the reform adds a new exemption to VAT covering the supply of electric energy used in irrigation systems/equipment for the agro-industrial sector.

Corporate income tax and related rules (Income Tax Law)

1) Tax loss indexation (effective for fiscal years beginning on/after January 1, 2025)

Tax losses generated in fiscal years beginning on/after January 1, 2025 will be indexed based on CPI (Argentine INDEC’s “IPC”) between the closing month of the fiscal year in which the tax loss originated and the closing month of the fiscal year being assessed.

2) Exemption for individual taxpayers’ term deposits is broadened (effective for fiscal years beginning on/after January 1, 2026)

The reform modifies the exemption rule for certain income from deposits by replacing the reference to term deposits “in local currency” with “term deposits”, extending the exemption to foreign denominated ones.

3) Housing/real estate-related exemptions for individuals is expanded (effective for fiscal years beginning on/after January 1, 2026)

The reform updates existing exemptions for individuals, now covering:

• The notional rental value of an owner-occupied home, and
• Income derived from leasing residential (non-commercial) property.

In addition, the reform provides that the gain on the sale of real estate (and transfer of rights over real estate) would be exempt for transfers occurring on or after January 1, 2026.

4) Sector-specific inventory valuation option for certain cattle activities (effective for fiscal years beginning on/after January 1, 2026)

5) Tax residence clarification for individuals obtaining citizenship by investment

Foreign individuals who obtain Argentine citizenship by naturalization due to relevant investments (under the Citizenship Law) will not be treated as Argentine tax residents solely as a result of such naturalization. Indeed, they will be considered as foreign national for Individual Income Tax purposes and general residency rules will apply to them. 

Repeal of selective consumption (excise-type) taxes

Effective as of the first day of the month immediately following the law’s entry into force, the reform eliminates the excise tax for certain categories, including:

• Insurance,
• Cellular and satellite telephony services,
• Luxury goods, and
• Certain automobiles/engines, recreational boats, and aircraft.

Incentive Regime for Medium-Sized Investments (RIMI)

The reform also creates the so-called “RIMI”, an incentive regime for MSMEs (up to Medium Segment 2) making qualifying “productive investments” in Argentina during the first two years from the regime’s effective date (as defined by regulations). Key benefits include:

• Optional accelerated income tax depreciation for qualifying new depreciable movable assets (excluding automobiles) and certain works, with one-year depreciation available for specified agricultural/energy-efficiency items and depreciable livestock; and
• Accelerated VAT input credit refunds tied to qualifying investments (available after three monthly VAT periods, under the regime’s rules).

To access RIMI benefits, productive investments made during the applicable two-year window must meet (at least) the following minimum amounts (by MSME category):

• Micro enterprises: USD 150,000
• Small enterprises: USD 600,000
• Medium enterprises – Segment 1: USD 3,500,000
• Medium enterprises – Segment 2: USD 9,000,000

ARCA (Federal Tax Authority) is expected to issue complementary and operational regulations for RIMI’s application, potentially involving other governmental areas as needed.