RIMI: Argentina's incentive regime for medium investments

Key rules

Status check of some secondary summaries

1. Legal basis and nature of the regime

Law 27.802, art. 177 creates RIMI "applicable throughout the territory of the Argentine Republic". Unlike RIGI, provinces do not need to adhere. RIMI covers only national taxes (income tax and VAT). It does nothing about provincial gross income tax, stamp tax or municipal levies. The stated aims (art. 178) are to encourage domestic and foreign medium investments, value chains, competitiveness, exports and employment. "Foreign" here refers to the source of the capital. The beneficiary must still be an Argentine taxpayer under ITL art. 53 (section 2).

Rulemaking is split as follows:

• The Executive regulated the regime by decree (Decree 242/2026, citing Constitution art. 99(2)).
• ARCA issues the "complementary, clarifying and operational" rules (Law 27.802, art. 188). It does so jointly with the SAGyP and the SE (Decree 242/2026, art. 11).
• The Ministry of Economy is empowered to specify the capital goods and types of work covered by accelerated depreciation (art. 182, last paragraph).
• The "Autoridad de Aplicación" may widen the exclusions (art. 184) and the exceptions to clawback (art. 186). The law does not name it. In practice, the operating norms have come from ARCA and the two Secretariats (unconfirmed).

2. Who qualifies (Law 27.802, art. 179; Decree 242/2026, art. 2; RGC 5849/2026, art. 2)

A beneficiary needs three things.

1. It is an ITL art. 53 taxpayer. That article covers corporations and other companies organised in Argentina, local trusts where the settlor is the beneficiary, sole proprietorships (empresas unipersonales), commission agents and other auxiliaries of commerce, and real estate developers (ITL art. 53(a) to (g)).
2. It qualifies as micro, small or medium up to tranche 2 under Law 24.467, art. 2 (Law 27.802, art. 179). Large companies are out.
3. It holds the "Certificado MiPyME" under Resolution 220/2019 of the former SME Secretariat. The certificate must be in force at the start of the fiscal year in which the first productive investment is made (Decree 242/2026, art. 2). RGC 5849/2026, art. 2(a) makes this precise. The certificate must be in force on the first day of the month in which that fiscal year starts, and the company must also be characterised in ARCA's "Sistema Registral" as micro, small or medium tranche 1 or 2. A company whose first investment falls in its first fiscal year of activity must hold the certificate when it makes the investment.

Non profit entities. Associations, foundations, mutuals, other civil entities and simple associations cannot obtain a MiPyME certificate. They may still qualify if they are registered with ARCA under form codes 86, 87, 203, 223 or 256 and meet the size parameters of Res. 220/2019, Annex I, arts. 2 to 12. They apply for classification to the Secretariat of Industry, Commerce and SMEs (RGC 5849/2026, art. 2(b)). ARCA then records the result under characterisation codes 646 (rejected) or 647 to 650 (micro, small, medium tranche 1, medium tranche 2). The characterisation lasts until the last day of the fourth month after the entity's fiscal year end. If the entity makes no investment in that time, it must apply again (art. 2(b)). Whether a non profit can be an ITL art. 53 taxpayer at all is a separate question that the RGC does not address (unconfirmed).

Size thresholds. The law does not set the size limits in money. It points to Law 24.467, art. 2 and the implementing resolution. The current annual sales caps published by the Ministry of Economy on argentina.gob.ar, in a table headed "actualizada a 2026", are below. Sales are the average of the last three closed fiscal years, net of VAT and excise taxes and after deducting 75% of exports (argentina.gob.ar, "¿Qué es una MiPyME?").

Annual sales caps in ARS. Source: image "tabla_ventas_anuales_actualizada_a_2026" on argentina.gob.ar. The page does not cite the resolution that set these amounts. For scale, the medium tranche 2 cap for industry is about US$ 82,994,481 at the MEP rate.

Other size rules from the same official page:

• Headcount instead of sales. Commission agents, consignees and travel agencies are classified by headcount: services 7 / 30 / 165 / 535 and commerce 7 / 35 / 125 / 345 for micro / small / medium tranche 1 / medium tranche 2.
• Asset cap. Companies whose main activity is financial intermediation, insurance or real estate services must also have assets of no more than ARS 3,438,000,000 (about US$ 2,198,350).
• Groups. A company that controls another, or is controlled by one (more than 50% of capital), is measured on consolidated group sales. If there are links with foreign companies, their total sales count and 100% of exports are included. Linked companies (20% to 50% holdings) must each register and qualify individually.
• Excluded activities. Domestic employers, extraterritorial bodies, public administration, gambling and betting, and partners or directors who do not carry on an independent business are excluded.

3. What counts as a productive investment (Law 27.802, art. 180; Decree 242/2026, arts. 3 to 5 and 8)

Movable goods. The goods must be new, amortisable for income tax, and not cars. They may be acquired, produced, manufactured or imported (art. 180). The decree narrows this. Only goods classified as capital goods (BK) or IT and telecom goods (BIT) in Annex I of Decree 557/2023 qualify (Decree 242/2026, art. 3). In practice, the tariff heading (NCM) of each asset decides whether it is in. Used goods are out. Spare parts and consumables that are not BK or BIT are out (unconfirmed).

Works. RIMI also covers works (obras), such as a new plant, warehouse or shed, "to be used directly in productive activities" in Argentina (art. 180). The decree counts:

• the share of the work carried out within the window;
• movable goods that form an inseparable part of the work or complement it; and
• installation costs (Decree 242/2026, art. 4).

Works already under way on 6 March 2026 qualify only if they were less than 30% complete on that date (art. 4). Progress is proven with invoices, a technical report from a qualified professional, progress certificates, a construction contract or other reliable evidence. Any professional's signature must be certified by the body that licenses them, and the evidence is uploaded to SGI (RGC 5849/2026, art. 4).

Promoted goods with no minimum (art. 180, last paragraph; Decree 242/2026, arts. 3 and 5):

• Irrigation systems and equipment. New amortisable goods that improve water management and distribution and boost farm productivity through precision technology (Decree 242/2026, art. 3(a)). The SAGyP list (Res. 75/2026, Annex I) covers NCM codes under the headings pivot, pumps (submersible and centrifugal), drip and sluice gates.
• Anti hail nets. High density polyethylene or similar mesh resisting hail of at least 20 mm, with UV protection, plus support structures, for crops (Decree 242/2026, art. 3(b)). Res. 75/2026, Annex II lists the net, posts, wires and tensioners by NCM code.
• Breeding animals. Animals for reproduction of superior genetics, pure pedigree or registered pure stock, recorded with breeders' associations or genetics companies (Decree 242/2026, art. 3(c)). Res. 75/2026, Annex III lists horses, cattle, pigs, sheep and goats, poultry and "other live animals" by NCM code. Its notes define the categories and name the recognised herd books (Sociedad Rural Argentina, the Stud Book Argentino of the Jockey Club Argentino and the Asociación Argentina de Fomento Equino). The animals must be used for reproduction in Argentina within formally registered production systems.
• High energy efficiency goods. Goods that generate, store or carry electricity from renewable sources, or that optimise, recover or reduce energy use in production units (Decree 242/2026, art. 5). The SE list (Res. 161/2026, Annex) currently covers only the generation and storage side:
• hydraulic turbines of more than 1,000 kW up to 10,000 kW (8410.12.00);
• photovoltaic generators (8501.31.20, 8501.80.00);
• wind generators above 700 kW (8502.31.00);
• transformers (8504.22.00, 8504.34.00);
• UPS units and AC converters (8504.40.40, 8504.40.90);
• containerised battery storage of up to 18 modules (8507.60.00.930A);
• photovoltaic modules or panels (8541.43.00).

To use the SE list, the SME must be registered in RENPER (renewable generation projects) or RENPALMA (storage projects), or hold a Usuario-Generador (distributed generation user) certificate (Res. SE 161/2026, art. 1). The SE delegated changes to the list, and further rules on art. 5(a) of the decree, to its Undersecretariat of Electric Energy (art. 2). No list has been found yet for the efficiency side, that is, goods that optimise, recover or reduce energy use (art. 5(b)) (unconfirmed).

Goods not on any list. Investments in these four categories that do not fit the published lists need a report by a qualified professional, with the signature certified by the licensing body. The SAGyP or the SE may review it (RGC 5849/2026, art. 3). ARCA must publish the eligible goods on its website (art. 3).

Excluded. Financial assets, portfolio investments and inventory (bienes de cambio) are excluded (art. 180). Decree 242/2026, art. 8 defines financial and portfolio assets by reference to ITL art. 2, fourth paragraph (shares, securities, quotas, digital currencies and similar). Land is not mentioned. It is neither a movable good nor a "work", and it is not depreciable, so it is outside the regime. Intangibles such as software licences are not "movable goods" and do not appear on the BK and BIT lists. They should be treated as excluded (unconfirmed).

4. Minimum investment (Law 27.802, art. 181; Decree 242/2026, art. 7)

How the minimum is measured (Decree 242/2026, art. 7):

• It is the sum of all eligible investments made within the window. The no minimum categories are left out of the sum (art. 7, first paragraph). Solar panels therefore get the benefits on their own, but they do not help a company reach its minimum for other assets.
• The amount is the invoice or equivalent document, net of VAT and of customary discounts (art. 7, second paragraph).
• Goods, works or inputs bought in pesos are converted at the Banco de la Nación Argentina buying rate on the business day before the invoice date. The same rate source applies to investments in a foreign currency other than USD (art. 7, third and fourth paragraphs). Goods invoiced in USD count at face value.
• SGI calculates the value of the investments that have a start up date. It also checks whether the minimum for the taxpayer's category has been reached (RG 5889/2026, Annex I, chapter D).

The minimum is a condition of the benefits, not a separate commitment. It is not secured by a guarantee and is not penalised if missed. If the minimum is not reached within the window, there are simply no benefits for assets subject to it (Decree 242/2026, art. 9).

5. The window: from 6 March 2026 to 19 May 2028 (with a legal caveat)

• The law. Investments made "during the first two (2) years counted from the date of entry into force of the regime, as established by the regulation" (art. 179).
• The decree. Investments made "from the entry into force of [Law 27.802] and up to two (2) years counted from the entry into force of the joint resolution" under art. 11 (Decree 242/2026, art. 1).
• The joint resolution. RGC 5849/2026 took effect on publication, 19 May 2026 (art. 7).
• ARCA's system. The first investment may not be dated before 6 March 2026. Invoices are accepted if issued on or before 19 May 2028 (RG 5889/2026, Annex I, chapter C(a) and (c)).

Our reading. ARCA has adopted the decree's longer window, and the law's words "as established by the regulation" give the decree some room. Still, a decree cannot extend a period fixed by statute. If "entry into force of the regime" means the law's publication, the statutory window closes on 6 March 2028. That gives an argument to deny benefits for invoices dated between 7 March and 19 May 2028. This risk is contested, not settled. A cautious investor should invoice and pay before 6 March 2028 and treat the last ten weeks as a buffer (unconfirmed).

Start up may come later. Assets bought within the window may be put into service after it closes, provided that, when bought, they were amortisable for income tax (Decree 242/2026, art. 6). "Start up" (puesta en marcha) means the asset or work is used to generate taxable income (art. 6). Under the law, the investment is "made" in the fiscal year of start up (art. 185). Benefits begin in that year (Decree 242/2026, art. 9).

6. Accelerated depreciation for income tax (Law 27.802, art. 182; RG 5889/2026, art. 5(b))

The beneficiary may choose between ordinary depreciation (ITL arts. 78, 87 and 88) and the RIMI schedule, starting with the fiscal year in which the asset goes into service:

Points the law adds:

• All or nothing. Once chosen, the option must be notified to ARCA. It then applies, without exception, to all productive investments made under the regime (art. 182, second paragraph). You cannot pick and choose asset by asset.
• How to notify. SGI is the channel. The information must be loaded before the due date of the income tax return in which the accelerated depreciation is claimed. The assets and depreciation in the return must match those reported in SGI (RG 5889/2026, art. 5(b)).
• Replacement assets (ITL art. 71). Where the taxpayer elects to apply the gain on a sold asset against the cost of its replacement, the special depreciation is computed on the reduced cost. If the sale and the replacement fall in different years, excess depreciation must be added back in the year of sale (art. 182, fourth and fifth paragraphs). The replacement must stay in the company's assets as required by art. 186. Otherwise, returns must be amended and the tax paid with interest. There is no loss of benefit if the amount reinvested is at least the sale price. A smaller reinvestment loses the benefit in proportion (art. 182, sixth and seventh paragraphs).
• Inflation adjustment. ITL art. 88(2) applies the art. 93 index (CPI for assets acquired in fiscal years starting from 1 January 2018) both to ordinary depreciation and to depreciation "made by the taxpayer under special rules". RIMI instalments are therefore also indexed. With only two instalments, the second year's charge is adjusted for one year of inflation. Under the general rule, ten instalments are each adjusted over a longer period (unconfirmed).

7. Early VAT refund (Law 27.802, art. 183; VAT Law art. 24; Decree 242/2026, art. 9; RG 5889/2026)

The general rule it builds on. Under the first unnumbered article after VAT Law art. 24, VAT paid on the purchase, construction, manufacture or import of depreciable fixed assets (except cars) is refunded under ARCA rules if it still forms part of the taxpayer's credit balance after six consecutive monthly periods. Capital goods VAT is set against output tax after all other input credits. The refund becomes final only if it is absorbed by later net VAT payments, or by export refund entitlements, within 60 periods. Otherwise the unused part must be repaid with interest. A fine of up to 100% applies to unused refunded amounts. Credits that have received any other "differential treatment" are excluded. The regime operates within an annual budget cap (VAT Law, art. 24, first unnumbered article).

What RIMI changes. For VAT credits generated by RIMI productive investments, the waiting time drops to three monthly periods counted from the period in which the credit could first be computed. The rest of the general rule applies "insofar as it does not conflict" with RIMI (art. 183). In particular, the 60 period absorption test, the clawback and the 100% fine all still apply (unconfirmed).

The budget cap. RIMI refunds may use no more than 50% of the annual cap fixed in the Budget Law for the art. 24 refund regime (Decree 242/2026, art. 9). For 2026 the national cap is ARS 30,000,000,000 (US$ 19,182,812.20) for requests filed in 2026 (Law 27.798, art. 38). The RIMI ceiling is therefore ARS 15,000,000,000 (US$ 9,591,406.10) for the whole country. Within RIMI, the cap is allocated by age of the balance (oldest period first) and, for balances of equal age, pro rata to their size (Decree 242/2026, art. 9). The 2027 cap depends on the 2027 Budget Law (unconfirmed). The ARS 30 billion figure is a nominal 2026 amount. Large refund claims could exhaust it, and nothing in the sources gives figures on demand.

How the refund is claimed (RG 5889/2026, art. 5(a) and Annex I, chapter D):

1. In SGI, once the investment has a start up date (and, where relevant, the minimum is met), the tab "Presentación de presolicitud SIR" lets the company file a pre-request and enter the allocation of the budget cap.
2. Pre-requests may be filed only on days 1 to 10 of February, May, August and November.
3. The allocation can be seen on days 11 to 15 of the same month in the tab "Consulta de Comprobantes con Suficiencia de Cupo Fiscal".
4. The company may renounce the allocation for one or more invoices. It may not move an allocation from one invoice to another, and it may not delete invoices unless it renounces. The VAT return period and the creditable VAT amount assigned to an invoice cannot be edited.
5. Once three monthly periods have passed from the period in which the credit was computable, the invoices with an allocation appear in SIR. There the company files the formal refund request under RG 5173 and its amendments.

The timing and form of payment after the SIR request are set by RG 5173, which is not in the sources for this page (unconfirmed).

8. Exclusions (Law 27.802, art. 184; Decree 242/2026, art. 10; RGC 5849/2026, art. 5)

The following cannot use RIMI:

The Autoridad de Aplicación may widen or change the exclusions (art. 184, closing paragraph).

What counts as a "final, enforceable and unpaid" debt. It is a debt that ARCA has formally demanded (intimada) and that the taxpayer has neither regularised nor appealed within the time given in the demand, counted from notification (Decree 242/2026, art. 10). ARCA checks this when the benefit is requested (RGC 5849/2026, art. 5). A payment plan or an appeal filed in time keeps the company in.

Later events. If any exclusion event happens after the company joins, both benefits are lost in full (art. 184, last paragraph).

Compared with the general VAT refund. The general art. 24 refund also excludes bankrupts without continuation and taxpayers indicted for tax crimes, that is, once the prosecutor has asked for trial (VAT Law, art. 24, first unnumbered article). RIMI requires a conviction confirmed on appeal. So RIMI is less strict on criminal matters, but it adds the unpaid debt test.

9. Holding period and loss of benefits (Law 27.802, art. 186)

If an asset that generated either benefit leaves the beneficiary's assets within two fiscal years of being put into service, the benefits lapse, except where:

• it is replaced by another asset of equal or higher value than the sale price of the one replaced;
• it is destroyed by an act of God or force majeure; or
• one third of its useful life has passed, on terms the regulation will set.

The Autoridad de Aplicación may add further exceptions (art. 186). Note that for an asset with a 10 year life, one third is about 3.3 years. That is longer than the two year holding period, so the third exception helps only for short lived assets (unconfirmed).

10. Revocation and penalties (Law 27.802, art. 187; RGC 5849/2026, art. 6)

Benefits are revoked by an express administrative act, after an administrative proceeding (sumario) in which the beneficiary can defend itself. The beneficiary must then pay back:

• the VAT credits refunded; and/or
• the income tax underpaid;
• plus compensatory interest (intereses resarcitorios);
• plus a fine of up to two times the benefit enjoyed, graded by ARCA (art. 187).

The SE and the SAGyP may audit compliance with their own rules and have access to SGI. If they detect a breach, they report it to ARCA, which claims the repayment, interest and fine (RGC 5849/2026, art. 6). The current interest rate is set by the Ministry of Economy under the Tax Procedure Law and is not in the sources for this page.

11. Interaction with other regimes

• RIGI (Law 27.742, Title VII). RIGI is not available to the same productive investments (Law 27.802, art. 184(f)). In practice the regimes hardly overlap. RIGI requires a single project vehicle and at least USD 200,000,000 (see /guide/investing/rigi/), while RIMI is for MiPyMEs.
• "Any other incentive regime" for the same investments is also excluded (art. 184(f)). Two cases are unclear:
• The general VAT refund (VAT Law art. 24). It is a general rule rather than a promotion regime. The RIMI refund is built on top of it (art. 183), so you cannot claim both on the same credit, and the general refund itself bars credits that received "differential treatment".
• Accelerated depreciation in another regime. Mining (Law 24.196) and forestry (Law 25.080) have their own depreciation rules (see /guide/taxes/tax-incentives/). One investment must sit in one regime only.
• Whether ARCA reads art. 184(f) as company wide (one regime makes the company ineligible) or per investment is not stated anywhere. The text says "for the same productive investments", which points to a per investment reading (unconfirmed).
• Foreign investment registration (Law 21.382). RIMI does not require any foreign investment filing and gives no FX benefits. A foreign shareholder funding a RIMI investment follows the general rules on capital contributions, FX inflows and later profit repatriation (see /guide/investing/foreign-investment-regime-21382/).
• Knowledge economy regime. A software company under Law 27.506 may in principle buy BIT servers under RIMI, since the KE benefits relate to income and payroll, not to the asset. The "any other incentive regime" exclusion makes this uncertain (unconfirmed).

RIMI compared with RIGI and with the general regime

RIGI entries are taken from the RIGI page of this guide and its sources (Law 27.742 and Decree 749/2024 as amended). For details, read /guide/investing/rigi/.

Deadlines and timing table

Timeline of norms

Also relevant: Law 27.798 (2026 Budget), art. 38, which sets the ARS 30,000,000,000 cap for 2026 art. 24 refunds.

Step by step

Who files: the company itself, through a representative with ARCA tax login (Clave Fiscal). Where: online only. The services involved are the MiPyME registry (form F.1272 at ARCA, then the certificate), SGI, the monthly VAT return, the annual income tax return, and SIR. Paper: none, except certified professional reports, which are uploaded as files.

1. Confirm size and certificate. Check the company's category against the sales table above, using the average of the last three fiscal years, net of VAT and 75% of exports, and consolidating any group. Make sure the MiPyME certificate is in force on the first day of the month in which the fiscal year of the first investment starts (RGC 5849/2026, art. 2(a)). The registry runs from ARCA form F.1272, according to the argentina.gob.ar page. Corrections are made by filing a rectified F.1272. Some cases are finished through the remote filing platform TAD (unconfirmed).
2. Meet the SGI access requirements (RG 5889/2026, art. 2):
3. CUIT in "Active" status (RG 3832);
4. registered for the relevant taxes;
5. an updated tax address without inconsistencies (Law 11.683, art. 3; RG 5809);
6. an updated activity code under the CLAE, form 883 (RG 3537);
7. an electronic tax address (Domicilio Fiscal Electrónico, RG 4280).
8. Clear exclusions. Check ARCA's records for any demanded and unpaid debt, and pay it, appeal it or put it on a payment plan within the term (Decree 242/2026, art. 10). Check that no partner, director or auditor has a conviction listed in art. 184.
9. Classify each asset. Find the NCM code. Check that it is BK or BIT in Decree 557/2023, Annex I, or that it is on Res. SAGyP 75/2026 or Res. SE 161/2026. If it is in a no minimum category but not on a list, get a report from a qualified professional with a certified signature (RGC 5849/2026, art. 3). For energy goods, register in RENPER or RENPALMA, or obtain the Usuario-Generador certificate (Res. SE 161/2026, art. 1).
10. For works in progress, gather invoices, progress certificates or a certified technical report showing less than 30% progress on 6 March 2026 (Decree 242/2026, art. 4; RGC 5849/2026, art. 4).
11. Register in SGI (RG 5889/2026, arts. 3 and 4 and Annex I, ch. C):
12. enter the start date of the first productive investment (not before 6 March 2026);
13. create one or more projects, which fix the location;
14. register each asset, work or farm and classify it by type (the system gives each item a unique code);
15. link the electronic invoices that ARCA already holds, or load others manually or by import;
16. enter the start up date of each item when it happens.
17. Select the benefits (RG 5889/2026, art. 5; Annex I, ch. B): accelerated depreciation, VAT refund, or both. They are not mutually exclusive.
18. Track the minimum. SGI calculates whether the investments with a start up date reach the minimum for the category (Annex I, ch. D). Keep your own file of the Banco Nación buying rates used for peso invoices (Decree 242/2026, art. 7).
19. VAT refund. File the pre-request in SGI on days 1 to 10 of February, May, August or November. Check the allocation on days 11 to 15. Once three periods have passed, file the formal request in SIR under RG 5173 (RG 5889/2026, Annex I, ch. D).
20. Depreciation. Load the depreciation information in SGI before the due date of the income tax return. Then claim the RIMI instalments in the return, matching SGI exactly (RG 5889/2026, art. 5(b)).
21. Keep the assets for two fiscal years from start up, or replace them with assets of equal or higher value (Law 27.802, art. 186). Watch the 60 period absorption test on refunded VAT (VAT Law, art. 24).
22. Keep evidence for audits by ARCA, the SE and the SAGyP (RGC 5849/2026, art. 6): invoices, customs declarations, technical reports, start up records and photographs.

Cost to do it.

• Fees: no government fee for the MiPyME certificate, SGI or SIR appears in any source (unconfirmed). Expect professional fees for the certified technical report (only where goods are off the lists or for works progress), for accountant work on the SIR refund (whether RG 5173 requires an accountant's report is not in the sources (unconfirmed)), and for tax advice on the depreciation election. No official fee scale for these is in the sources.
• Capital: the minimum investment itself, from USD 150,000 (micro) to USD 9,000,000 (medium tranche 2), or any amount for the listed no minimum goods.
• Months:
• SGI registration can be done as soon as the first invoice exists.
• The first VAT refund cash arrives at the earliest after three monthly periods and after the next quarterly pre-request window. Allow 4 to 7 months from the purchase, plus RG 5173 processing time (unconfirmed).
• The depreciation benefit arrives with the annual income tax return for the start up year (and, in part, through lower advance payments (unconfirmed)).

Worked examples

Facts (assumptions marked).

• "Metalúrgica Andina SA" is a small industrial company with a valid MiPyME certificate. Its fiscal year is the calendar year.
• In July 2026 it imports and puts into service a new CNC machining centre classified as BK. It is invoiced at USD 2,000,000 net of VAT. That beats the small company minimum of USD 600,000 (art. 181(b)). Because the invoice is in USD, the minimum test needs no conversion (Decree 242/2026, art. 7).
• For the peso tax cost we use the MEP rate for illustration: 2,000,000 × 1,563.90 = ARS 3,127,800,000. In real life the income tax cost is the peso value under the ITL import rules, not the MEP rate.
• Assumed useful life under the general rule: 10 years [assumption]. The full annual charge is taken in the year of start up [assumption; check the ITL rules on the first year].
• Taxable income before depreciation of this machine: ARS 2,000,000,000 a year, flat for 10 years [assumption].
• The 2026 corporate scale applies in every year (25% up to ARS 133,514,185.74; ARS 33,378,546.43 plus 30% up to ARS 1,335,141,857.38; ARS 393,866,847.93 plus 35% above that) [ARCA "Escala 2026"; assumption that brackets stay the same in real terms. They are indexed each year, so ].
• Inflation indexation of depreciation (ITL arts. 88(2) and 93) is ignored, and all figures are nominal [simplification].
• VAT on the import at 10.5% [assumption that the NCM code is on the reduced rate list of VAT Law art. 28(e); otherwise 21%; classification]. VAT and income tax perceptions at customs are ignored (unconfirmed).

Step 1: depreciation per year.

• General: 3,127,800,000 / 10 = ARS 312,780,000 a year (US$ 200,000) for years 1 to 10 (ITL art. 88(1)).
• RIMI: 3,127,800,000 / 2 = ARS 1,563,900,000 (US$ 1,000,000) in years 1 and 2, nothing after (art. 182(a)).
• Extra deduction under RIMI in each of years 1 and 2: 1,563,900,000 − 312,780,000 = ARS 1,251,120,000 (US$ 800,000). This is fully reversed over years 3 to 10 (8 × 312,780,000 = 2,502,240,000 = 2 × 1,251,120,000).

Step 2: income tax per year with the progressive scale.

• General, each year: taxable income 2,000,000,000 − 312,780,000 = 1,687,220,000. Tax = 393,866,847.93 + 35% × (1,687,220,000 − 1,335,141,857.38) = 393,866,847.93 + 123,227,349.92 = ARS 517,094,197.85 (US$ 330,644.03).
• RIMI, years 1 and 2: taxable income 2,000,000,000 − 1,563,900,000 = 436,100,000. Tax = 33,378,546.43 + 30% × (436,100,000 − 133,514,185.74) = 33,378,546.43 + 90,775,744.28 = ARS 124,154,290.71 (US$ 79,387.61).
• RIMI, years 3 to 10: taxable income 2,000,000,000. Tax = 393,866,847.93 + 35% × (2,000,000,000 − 1,335,141,857.38) = ARS 626,567,197.85 (US$ 400,644.03).

Step 3: read the result.

• Cash flow. In each of the first two years the company keeps ARS 392,939,907.14 (US$ 251,256.41) that it would otherwise pay. That is ARS 785,879,814.28 (US$ 502,512.83) over two years. It pays back ARS 109,473,000 (US$ 70,000) a year in years 3 to 10, which is ARS 875,784,000 (US$ 560,000) in total.
• Total nominal tax rises by ARS 89,904,185.72 (US$ 57,487.17). The reason: in years 1 and 2 the big deduction pushes taxable income down into the 30% bracket, so part of the deduction saves only 30%. The reversal in years 3 to 10 is taxed at 35%. This is a real feature of combining RIMI with a progressive scale. It is not a mistake in the regime.
• Whether RIMI is still worth it depends on the company's cost of money. Deferring ARS 785.9 million for an average of several years is usually worth more than ARS 89.9 million. But that is a financial judgement this page cannot make for you, and the sources give no discount rate. Run your own model using your peso borrowing cost and expected inflation.
• With taxable income always in the 35% bracket (for example, a pre-depreciation profit of ARS 4 billion), there is no bracket effect. The timing difference is then simply 35% × 1,251,120,000 = ARS 437,892,000 (US$ 280,000) deferred in each of years 1 and 2, and 35% × 312,780,000 = ARS 109,473,000 (US$ 70,000) repaid in each of years 3 to 10. Total tax over ten years is equal.
• The election covers everything. Because the choice applies to all RIMI investments (art. 182), a company with low profits in the first years should model every planned asset before electing.

Step 4: VAT timing.

• Import VAT at 10.5%: 10.5% × 3,127,800,000 = ARS 328,419,000 (US$ 210,000), computable in the July 2026 return.
• Assume the company's net VAT position from other activity, meaning output tax minus all other input credits, is a payable of ARS 40,000,000 (US$ 25,577.08) a month [assumption]. Capital goods VAT is used only after other credits (VAT Law, art. 24, first unnumbered article).

Practical calendar under RIMI: file the SGI pre-request in the 1 to 10 August 2026 window after start up, and see the allocation on 11 to 15 August. The invoice reaches SIR after three periods. Counting the periods after July, that is after October 2026 (unconfirmed). The formal request follows under RG 5173. The lesson: the earlier refund matters most to companies whose net VAT payable is small compared with the credit, such as start ups, exporters and businesses selling at the 10.5% rate. A company with large monthly output VAT absorbs the credit within months anyway. This claim of ARS 328,419,000 would use about 2.19% of the RIMI share of the 2026 cap (ARS 15,000,000,000).

Risk check. If the company sells the machine in 2027, within two fiscal years of start up, without buying a replacement of equal or higher value, both benefits lapse (art. 186). It must then repay the deferred tax (ARS 392,939,907.14 for FY 2026) and any refunded VAT with interest, and it faces a fine of up to twice those amounts (art. 187).

Facts.

• "Conservas del Valle SA" is an Argentine food processor, classified under industry. Its fiscal year is the calendar year.
• It is 100% owned by two Argentine resident individuals, with no foreign affiliate.
• Average annual sales for the last three closed years, net of VAT: ARS 70,000,000,000, of which exports are ARS 16,000,000,000.
• Investment plan for 2026 and 2027:
• (i) a new packaging line, NCM code BK, imported, USD 1,800,000;
• (ii) a warehouse extension costing ARS 2,500,000,000 in total, of which 20% (ARS 500,000,000) was spent before 6 March 2026;
• (iii) rooftop photovoltaic panels, NCM 8541.43.00, USD 250,000;
• (iv) a used forklift, USD 300,000;
• (v) a pick up truck, USD 60,000;
• (vi) ERP software licences, USD 120,000.

Step 1: size. Sales for classification = 70,000,000,000 − 75% × 16,000,000,000 = 70,000,000,000 − 12,000,000,000 = ARS 58,000,000,000 (about US$ 37,086,770 at MEP). Industry caps: small up to ARS 9,025,610,000; medium tranche 1 up to ARS 64,238,670,000. The company is Medium tranche 1. Its minimum is USD 3,500,000 (art. 181(c)).

Step 2: certificate timing. The first investment is in 2026, so the certificate must be in force on 1 January 2026, the first day of the month in which FY 2026 starts (RGC 5849/2026, art. 2(a)). If the certificate had lapsed at that date, the company should check whether the first investment can be moved into FY 2027 with a certificate in force on 1 January 2027 (unconfirmed).

Step 3: classify each item.

Step 4: convert the peso item. The warehouse invoices must each be converted at the Banco Nación buying rate on the business day before each invoice (Decree 242/2026, art. 7). For this illustration only, we use the MEP rate of 1,563.90 [the real calculation needs the BNA rate per invoice; ]: 2,000,000,000 / 1,563.90 = USD 1,278,854.15.

Step 5: test the minimum. USD 1,800,000 + USD 1,278,854.15 = USD 3,078,854.15. The minimum is USD 3,500,000. Shortfall: USD 421,145.85. As planned, the company gets no benefit on items (i) and (ii) (Decree 242/2026, art. 9). Item (iii) still qualifies for one instalment depreciation and the early VAT refund, because it has no minimum.

Step 6: fix the plan. Options:

• Add eligible BK or BIT purchases of at least USD 421,145.85 before the window ends (19 May 2028 per SGI; 6 March 2028 under the cautious reading). Examples are a new forklift instead of a used one, or new servers.
• Accept that items (i) and (ii) stay under the general regime.

Peso inflation and a stronger peso both change the USD value of the warehouse spending. Track it invoice by invoice.

Step 7: other checks.

• No demanded and unpaid ARCA debt (Decree 242/2026, art. 10).
• No convictions affecting directors (art. 184(e)).
• Items not claimed under any other regime (art. 184(f)).
• The company plans to keep all items for at least two fiscal years after start up (art. 186).

Variant: a foreign owned company. Suppose the same company were 60% owned by a Spanish food group with sales of EUR 900 million. The group's consolidated sales would be used, including the foreign parent and with 100% of exports. The company would almost certainly not be a MiPyME (argentina.gob.ar, "Relaciones de vinculación y control"). It would be outside RIMI altogether. Its only national option for incentives would be RIGI, if the project reached USD 200 million, or a sector regime (see /guide/taxes/tax-incentives/).

Practical traps

• The certificate date is unforgiving. RIMI looks at the certificate on the first day of the month in which the fiscal year starts, not at the date of purchase (RGC 5849/2026, art. 2(a)). Renew the certificate before each fiscal year starts.
• Foreign groups rarely qualify. Consolidation includes foreign affiliates and all their exports. Most subsidiaries of multinationals are "large" for MiPyME purposes. Check this first.
• The no minimum goods do not count toward the minimum (Decree 242/2026, art. 7). Do not count solar panels or irrigation pivots when testing the USD threshold for your other assets.
• BK or BIT classification is decisive. A machine that is not BK or BIT in Decree 557/2023, Annex I is not a RIMI good, however productive it is (Decree 242/2026, art. 3). Get the customs broker to confirm the NCM code before ordering.
• New goods only. Used imports and second hand local purchases are excluded (art. 180).
• Works: only the part within the window counts, and only if the work was less than 30% complete on 6 March 2026 (Decree 242/2026, art. 4). Document progress at that date now, while evidence is available.
• The depreciation election is all or nothing (art. 182). It also must be loaded in SGI before the income tax return due date, and the return must match SGI (RG 5889/2026, art. 5(b)). A mismatch invites a challenge.
• The progressive scale can make RIMI cost more tax in total (Example 1). Model it.
• The VAT refund is capped and quarterly. RIMI shares at most half of a fixed national cap (Decree 242/2026, art. 9; Law 27.798, art. 38). The cap is allocated by age of balance, and pre-requests open only four times a year (RG 5889/2026, Annex I). Missing the 1 to 10 window costs three months.
• Refunded VAT must be absorbed within 60 periods or repaid with interest (VAT Law, art. 24). A company that expects to keep a permanent credit balance (for example, one selling mostly at 10.5% while buying at 21%) should check this before claiming.
• Assets must stay two fiscal years. Selling, transferring to a related company or moving equipment out of the country within that period triggers clawback (art. 186) and a fine of up to 2× (art. 187).
• An unpaid demand can sink the claim. ARCA checks for demanded and unpaid debt when the benefit is requested (RGC 5849/2026, art. 5). Answer every ARCA demand within its term, by paying, appealing or joining a plan.
• Benefits lapse for events after joining. A director's tax crime conviction confirmed on appeal, or a bankruptcy, ends both benefits (art. 184, last paragraph).
• Using MEP or CCL rates for the minimum is wrong. The rule is the BNA buying rate on the business day before each invoice (Decree 242/2026, art. 7).
• The end date is contested. Do not rely on the period from 7 March to 19 May 2028 unless you have to (section 5).
• Provincial taxes are untouched. RIMI does nothing for gross income tax or stamp tax on the purchase contracts. Check provincial regimes separately.

Recent changes

• 6 March 2026. Law 27.802 published. Title XXIII creates RIMI (arts. 177 to 188).
• 13 April 2026. Decree 242/2026 published. It sets the window (art. 1), the certificate rule (art. 2), the BK and BIT limit (art. 3), works and the 30% rule (art. 4), energy efficiency (art. 5), late start up (art. 6), minimum conversion (art. 7), the 50% of VAT cap rule (art. 9), the definition of unpaid debt (art. 10) and the order for joint rules within 30 days (art. 11).
• 19 May 2026. RGC 5849/2026 published. It sets up SGI, the certificate on the first day of the fiscal year month, the non profit route, lists and professional reports, proof of works progress and controls.
• 8 June 2026. Res. SAGyP 75/2026 published, with lists for irrigation, anti hail nets and breeding animals.
• 14 July 2026. Res. SE 161/2026 published, with the list of electricity generation, storage and transport goods. RENPER, RENPALMA or Usuario-Generador status is required.
• 25 August 2026. RG ARCA 5889/2026 published. It implements SGI with RIMI as regime code 1, the quarterly VAT pre-request windows, invoice dates from 6 March 2026 to 19 May 2028, and the rule that depreciation information goes in before the income tax return is due. SGI is meant to replace gradually the procedures for other investment regimes too (recitals of RG 5889/2026).

Pending changes

1. Ministry of Economy list of capital goods and works (art. 182, last paragraph). Not issued as far as Infoleg shows up to 20 October 2026 (unconfirmed).
2. Energy efficiency goods (Decree 242/2026, art. 5(b)) have no list yet. Res. SE 161/2026 covers generation, storage and transport only (unconfirmed).
3. Definition of "one third of useful life" for the clawback exception (art. 186(c)) awaits regulation (unconfirmed).
4. Autoridad de Aplicación. The law does not name it (unconfirmed).
5. End of the window. There is a conflict between the statute (two years from entry into force) and the decree and ARCA system (19 May 2028) (unconfirmed).
6. 2027 refund cap. It depends on the 2027 Budget Law (unconfirmed).
7. ARCA microsite "Inversiones." RG 5889/2026, art. 1 refers to it for functional guidance. It was not consulted for this page (unconfirmed).
8. Late minimum. If the minimum is reached in a later year, it is unclear whether depreciation can be claimed retroactively for assets started up earlier, by amending returns (unconfirmed).
9. Category changes. If a company moves from small to medium tranche 1 during the window, it is unclear which minimum applies. SGI uses "the category of the taxpayer" (RG 5889/2026, Annex I, ch. D) without fixing the date (unconfirmed).

FAQ

1. Is RIMI law, or still a bill? It is law. It is Title XXIII of Law 27.802, published in the BO on 6 March 2026 and in force from publication (art. 217). It is regulated by Decree 242/2026 (BO 13 April 2026), RGC 5849/2026 (BO 19 May 2026) and RG 5889/2026 (BO 25 August 2026).

2. Can a foreign investor use RIMI? Only through an Argentine taxpayer (ITL art. 53) that qualifies as a MiPyME (art. 179). Foreign ownership is allowed in principle, and the regime's stated aim includes foreign investment (art. 178). But group consolidation usually makes a subsidiary of a foreign group "large". A foreign individual or small foreign fund owning a local SME can benefit if the SME stays within the caps. Capital inflows follow the general rules (see /guide/investing/foreign-investment-regime-21382/).

3. Does RIMI lower the income tax rate? No. It only brings depreciation forward (art. 182). The rate scale is unchanged. RIGI is the regime with a flat 25% rate (Law 27.742, art. 183(a)).

4. What is the minimum investment for my company? USD 150,000 (micro), USD 600,000 (small), USD 3,500,000 (medium tranche 1) or USD 9,000,000 (medium tranche 2) (art. 181). It is measured as the sum of all eligible investments in the window, net of VAT, and converted at the BNA buying rate for peso invoices (Decree 242/2026, art. 7). Irrigation, energy efficiency goods, anti hail nets and breeding animals have no minimum (art. 180).

5. Do I need approval before investing? No prior approval is required. The company registers its investments and chooses its benefits in SGI (RGC 5849/2026, art. 1; RG 5889/2026). ARCA checks for unpaid debts when the benefit is requested (RGC 5849/2026, art. 5). The SE and SAGyP may audit (art. 6). Items outside the lists need a certified professional report, which the Secretariats may review (art. 3).

6. Can I buy a car, a pick up or used machinery? Cars are expressly excluded, and only new goods qualify (art. 180). Whether a pick up truck counts as a car is not defined in the RIMI norms (unconfirmed). Used machinery is out.

7. How fast is the VAT refund? Credits become eligible after three monthly periods (art. 183). You file a pre-request in SGI on days 1 to 10 of February, May, August or November, and then the formal request in SIR under RG 5173 (RG 5889/2026, Annex I). Payment depends on the RIMI share of the national cap (ARS 15,000,000,000 in 2026) and on RG 5173 processing (unconfirmed).

8. What happens if I sell the asset early? If the asset leaves the company within two fiscal years of start up, both benefits lapse unless it is replaced with one of equal or higher value, destroyed by force majeure, or one third of its useful life has passed (art. 186). On revocation you repay the tax and VAT with interest, plus a fine of up to twice the benefit (art. 187).

9. Can I combine RIMI with RIGI or another regime? Not for the same productive investments (art. 184(f)). You may use different regimes for different assets, as long as no single asset or VAT credit gets two treatments. ARCA's reading of "any other incentive regime" has not been published (unconfirmed).

10. When is the last date to invest? ARCA's SGI accepts invoices dated up to and including 19 May 2028 (RG 5889/2026, Annex I, ch. C(c)). The law's own two year period could be read as ending on 6 March 2028 (art. 179). For safety, invoice before 6 March 2028. Assets bought in time may start up later (Decree 242/2026, art. 6).

11. Is a non profit eligible? Associations, foundations, mutuals and similar entities that cannot obtain a MiPyME certificate can be classified by the Secretariat of Industry, Commerce and SMEs and characterised by ARCA under codes 647 to 650 (RGC 5849/2026, art. 2(b)). The fit with the ITL art. 53 requirement is untested (unconfirmed).

12. Does RIMI help with provincial taxes or import duties? No. RIMI covers national income tax and VAT only (arts. 182 and 183). Import duties, the statistics fee, gross income tax and stamp tax follow their own rules (see /guide/taxes/tax-incentives/).

Primary sources

• Law 27.802, *Ley de Modernización Laboral*, Title XXIII (arts. 177 to 188), art. 217. Sanctioned 27 Feb 2026, BO 6 Mar 2026. Infoleg
• Infoleg list of norms that amend or complement Law 27.802 (consulted 26 Oct 2026)
• Decree 242/2026, signed 10 Apr 2026, BO 13 Apr 2026
• Joint General Resolution 5849/2026 (ARCA, SE, SAGyP), BO 19 May 2026
• Resolution SAGyP 75/2026, BO 8 Jun 2026, with Annexes I to III
• Resolution SE 161/2026, BO 14 Jul 2026, with Annex
• ARCA General Resolution 5889/2026, BO 25 Aug 2026, with Annex I
• Ministry of Economy, "¿Qué es una MiPyME?", argentina.gob.ar

Related pages

• /guide/investing/rigi/
• /guide/taxes/tax-incentives/
• /guide/investing/foreign-investment-regime-21382/
• Bilateral investment treaties and ICSID protection for investors in Argentina
• Restricted sectors and limits on foreign investment in Argentina
• Are there restrictions on foreign investment in Argentina?
• What is the RIGI and who qualifies?
• RIGI approved projects tracker