Tax incentives in Argentina: national promotion regimes, RIGI, knowledge economy, SMEs and regional regimes

Key rules

Map of national incentives at a glance

1. RIGI in one paragraph (Law 27.742, Title VII; Decree 749/2024)

RIGI is designed for single projects of at least USD 200,000,000 in forestry industry, tourism, infrastructure, mining, technology, steel, energy, and oil and gas (arts. 167 and 173). Its tax package is a flat 25% corporate rate (art. 183(a)), optional accelerated depreciation (art. 183(b)), unlimited and transferable loss carryforward (art. 183(c)), a 7% final tax on dividends and branch remittances falling to 3.5% after seven years (arts. 184 and 185), 100% of the bank debit and credit tax creditable against income tax (art. 189), VAT on capital goods settled with tax credit certificates (art. 187), no import duties on capital goods (art. 190), and no export duties after three years (art. 191). Stability lasts 30 years (arts. 201, 202 and 205). Sanctions run from ARS 10,000,000 (US$ 6,394.27) to 15% of the pending minimum investment, with loss and repayment of benefits (art. 213). The stacking rule is in art. 208: RIGI benefits may not be added to incentives "of the same nature" from other regimes, but RIGI does not prevent combining incentives "of a different nature that do not overlap". Everything else, including the procedure, sector minimums and FX rules, is on /guide/investing/rigi/.

2. RIMI: the medium investment regime (Law 27.802, arts. 177 to 188)

Status. Enacted. Law 27.802 (Ley de Modernización Laboral) was sanctioned on 27 February 2026 and published in the BO on 6 March 2026; its articles apply from publication unless stated otherwise (art. 217). Title XXIII is regulated by Decree 242/2026 (signed 10 April 2026, BO 13 April 2026) and by Joint General Resolution (RGC) 5849/2026 of ARCA, the Secretariat of Energy and the Secretariat of Agriculture, Livestock and Fisheries (signed 18 May 2026, BO 19 May 2026). The lists of agricultural goods that qualify without a minimum were approved by Secretariat of Agriculture Resolution 75/2026 (signed 5 June 2026; BO 8 June 2026 per the Infoleg index).

Who. Entities listed in ITL art. 53 (companies and similar) that qualify as micro, small or medium companies "up to Mediana Empresa Tramo 2 inclusive" under art. 2 of Law 24.467 (Law 27.802, art. 179). The company must hold the MiPyME certificate under Resolution 220/2019 of the former SME Secretariat, valid at the start of the fiscal year of the first productive investment (Decree 242/2026, art. 2), and must be characterised in ARCA's "Sistema Registral" as micro, small or medium tranche 1 or 2. RGC 5849/2026, art. 2(a) refines this: the certificate must be valid on the first day of the month in which the fiscal year starts, and a company making its first investment in its first year of activity must hold the certificate when it invests. Non profit entities that cannot get a certificate may qualify by registering under one of five legal form codes and obtaining a size classification from the Secretariat of Industry, Commerce and SMEs (RGC 5849/2026, art. 2(b)).

What qualifies. "Productive investments": acquisition, production, manufacture or import of new movable goods (except cars) that are amortisable for income tax, and works, used directly in productive activities in Argentina (art. 180). The decree narrows movable goods to those classified as capital goods (BK) or IT and telecom goods (BIT) in Annex I of Decree 557/2023 (Decree 242/2026, art. 3). Works include the share of works carried out within the window, the movable goods that form an inseparable part of them and installation costs; works that were less than 30% complete when the law came into force also qualify (Decree 242/2026, art. 4), proven with invoices, a certified professional report or progress certificates (RGC 5849/2026, art. 4). Financial assets, portfolio investments and inventory are excluded (art. 180; Decree 242/2026, art. 8).

Minimum investment (art. 181), counted as the sum of eligible investments in the window, net of VAT and discounts, converted at the Banco Nación buying rate of the business day before each invoice (Decree 242/2026, art. 7):

Benefits.

• Accelerated depreciation (art. 182). Optional, from the year the asset is put to use. Movable goods: two equal annual instalments. Works: at least the number of annual instalments resulting from 60% of estimated useful life. Agricultural irrigation and high energy efficiency equipment, breeding animals and anti hail nets: one instalment. Once chosen, the option must be notified to ARCA and applied to all RIMI investments. For mineral assets depleted under ITL art. 78 the depletion charge is multiplied by 1.6. The Ministry of Economy may list the goods and works covered.
• Early VAT refund (art. 183). VAT credits from RIMI investments that form part of the taxpayer's balance may be refunded after three monthly periods (instead of six under the general regime). The refunds share the general budget cap of VAT Law art. 24: RIMI may use no more than 50% of the annual cap, allocated first to the oldest balances and, for equal age, pro rata (Decree 242/2026, art. 9). For 2026 the cap is ARS 30,000,000,000, so the RIMI ceiling is about ARS 15,000,000,000 (US$ 9,591,406.10) for the whole country.

When. Benefits apply in the fiscal year in which the investment is put into service (puesta en marcha) and, if a minimum applies, once it has been reached within the window (art. 185; Decree 242/2026, arts. 6 and 9). Investments made in the window may start up after it closes if they were amortisable when made (Decree 242/2026, art. 6).

The window, and an inconsistency. The law speaks of investments made "during the first two years counted from the entry into force of the regime" (art. 179). The decree says investments made from the entry into force of the law and "up to two years counted from the entry into force of the joint resolution" (Decree 242/2026, art. 1). RGC 5849/2026 came into force on publication, 19 May 2026 (art. 7). Read literally, the decree window runs from 6 March 2026 to about 19 May 2028, which is longer than a two year period counted from 6 March 2026. A decree cannot extend a statutory deadline, so a conservative investor should aim to have investments invoiced by 6 March 2028 (unconfirmed).

Exclusions (art. 184): companies or shareholders convicted under Law 27.401 (corporate criminal liability); bankrupts; those convicted under the tax, customs or FX criminal laws; companies whose officers have such convictions; those with final, enforceable and unpaid tax, customs or social security debts (meaning debts demanded by ARCA and neither regularised nor appealed within the term given, Decree 242/2026, art. 10; ARCA checks this when the benefit is requested, RGC 5849/2026, art. 5); and entities that obtain RIGI or any other incentive regime for the same productive investments (art. 184(f)). Any of these events after joining causes total loss of both benefits.

Clawback and penalties. If the assets leave the company within two fiscal years of being put to use, both benefits lapse, unless the asset is replaced by another of equal or higher value, destroyed by force majeure, or one third of its useful life has passed (art. 186). On revocation, the company must repay refunded VAT and income tax underpaid, with interest, plus a fine of up to two times the benefit, graded by ARCA after an administrative proceeding (art. 187; RGC 5849/2026, art. 6).

Procedure system. Registration of investments, choice of benefits and management run through an ARCA web service called "Sistema de Gestión de Inversiones (SGI)" (RGC 5849/2026, art. 1).

3. Knowledge Economy Regime (Law 27.506, as amended)

Legal basis. Law 27.506 (sanctioned 22 May 2019, BO 10 June 2019), substantially rewritten by Law 27.570 (BO 26 October 2020), with arts. 8, 15(e), 18 and 19 later replaced by Decree 679/2022 (BO 11 October 2022) according to the Infoleg updated text. Regulated by Decree 1034/2020 (BO 21 December 2020) and its Annex. The Infoleg updated text shows no amendment to the benefit articles after 2022 (unconfirmed).

Promoted activities (art. 2). Software and IT and digital services (including SaaS, custom development, cloud computing and video games); audiovisual production and post production; biotechnology, bioeconomy and related sciences; geological and prospecting services and electronics and communications services; export professional services (legal, accounting, management consulting, translation, HR, advertising, design, architecture and engineering); nanotechnology; aerospace and satellite; nuclear engineering; Industry 4.0 automation; and R&D in engineering, exact, natural, agricultural and medical sciences.

Who qualifies (art. 4). Legal entities incorporated in Argentina or authorised to operate there, up to date with tax, labour, union and social security obligations, that carry out promoted activities in Argentina on their own account as their main activity. Registration in the National Register of Beneficiaries requires:

• 70% of total revenue of the last year from promoted activities (art. 4.II(a); Decree 1034/2020, Annex, art. 1), or proof of intensive development of promoted activities for companies without such revenue (art. 4.II(b)); and
• at least two of three additional requirements: (1) continuous quality improvement or a recognised quality standard; (2) training spend of at least 1% (micro), 2% (small and medium) or 5% (large) of payroll, or R&D spend of at least 1% (micro), 2% (small and medium) or 3% (large) of revenue; (3) exports of at least 4% (micro), 10% (small and medium) or 13% (large) of revenue. Export professional services must meet requirements 1 and 2, and use the large company percentages for requirement 2.
• Micro companies under three years old need only prove that promoted activities are their main activity; they must meet the full test after four years or when they stop being micro (art. 6).
• In house development for the company's own use or for related companies does not count toward the 70% (art. 5).

Benefits.

Costs of being in the regime. Two charges reduce the net benefit:

• an audit and verification fee of up to 4% of the tax benefits obtained (art. 13) (unconfirmed); and
• a contribution to FONPEC, the KE trust fund, of 1% (micro), 2.5% (small and medium) or 3.5% (large) of total benefits received (art. 18.III.1(a); Decree 1034/2020, Annex, art. 21).

Revalidation and monitoring. Every two years, the beneficiary must prove compliance, maintain or increase headcount and increase the additional requirements by a percentage set by the authority (art. 4.III; Decree 1034/2020, Annex, art. 6). Headcount must be reported annually; a reduction must be made good with new hires within 60 days, with listed exceptions such as resignation, dismissal for cause, retirement or end of fixed term (Annex, art. 7). Changes in the chosen additional requirements must be notified within 15 business days and only once a year (Annex, art. 13).

Sanctions (art. 15). Suspension of benefits for 3 months to 1 year, removal, revocation (possibly retroactive to registration), payment of taxes not paid with interest, return of bonds, disqualification and fines up to 100% of the benefit. Benefits fall automatically (art. 15 bis) if headcount drops for more than 60 days, unregistered workers are found, the company enters REPSAL or fraud is verified.

Quota. The bonds are subject to a fiscal quota set in the annual budget (art. 8). For 2026: ARS 310,000,000,000 (US$ 198,222,392.74) (Law 27.798, art. 39). If the quota runs out, bond issue may be delayed (unconfirmed).

Sunset. 31 December 2029 (art. 20). There is no rule in the sources on what happens to unused bonds after that date, apart from the 24 month validity in art. 8 (unconfirmed).

4. SME benefits (Law 27.264) and the MiPyME certificate

Legal basis. Law 27.264, Programa de Recuperación Productiva (BO 1 August 2016), Title II "special tax treatment" and Title III "investment promotion". Beneficiaries must be micro, small or medium companies "in the terms of art. 1 of Law 25.300" (art. 4). The size categories are defined by the enforcement authority on the basis of employees, sales and assets, reviewed yearly, and companies linked to or controlled by groups that exceed the limits are excluded (Law 25.300, art. 1, as replaced by Law 27.264, art. 32). The current classification is Resolution 220/2019 of the former SME Secretariat and amendments, cited by Decree 242/2026, art. 2 and RGC 5849/2026, art. 2. The sales, employee and asset limits by sector are not in the source files (unconfirmed).

Clawback under Title III (still relevant for audits of 2016 to 2018 investments): if employment fell in the year of the benefit or the next, or assets left the company before one third of their useful life, the company had to repay the benefit with interest and a 100% fine, demanded by simple intimation without the normal LPT assessment procedure (arts. 18 and 19).

Why the certificate matters beyond Law 27.264. The MiPyME certificate is also the gateway to RIMI (Decree 242/2026, art. 2), to the size based KE percentages (Law 27.506, arts. 4 and 10, using Law 24.467 art. 2 categories) and to the 18% versus 20.40% employer contribution split for services and commerce (Law 27.541, art. 19, see the payroll page). Because RIMI requires the certificate to be valid at the start of the fiscal year (RGC 5849/2026, art. 2(a)), a company that lets it lapse loses RIMI for investments in that year.

5. VAT refund on capital goods and accelerated depreciation outside special regimes

General regime (permanent). Law 27.430, art. 92 (BO 29 December 2017) added the first unnumbered article after art. 24 of the VAT Law. VAT credits from the purchase, construction, manufacture or final import of capital goods (bienes de uso, amortisable for income tax, except cars) that remain in the taxpayer's favour after six consecutive monthly periods are refunded. The rule also covers VAT on goods used for exports. Key conditions in the same article:

• capital goods credits are imputed last, after all other credits of the taxed activity;
• the refund becomes final only to the extent that later VAT actually paid (or, for exports, the export refund that would have applied) absorbs it; if not absorbed within 60 periods, the excess must be returned with interest, also on cessation, dissolution or a non tax free reorganisation;
• goods acquired by leasing: credits count only after six periods from exercise of the purchase option, unless the lease is treated as a sale for income tax;
• no refund if the credits received any other special treatment, and no other special treatment may be claimed once this refund is requested;
• fine of up to 100% of amounts refunded and not applied; exclusions for bankrupts and for persons under criminal tax prosecution with an indictment request.

The regime applies to balances whose right to compute arises from the first day of the month after Law 27.430 came into force (Law 27.430, art. 97, second paragraph), so from January 2018 (unconfirmed). The annual budget caps the total: ARS 30,000,000,000 (US$ 19,182,812.20) for requests filed in 2026, allocated by a mechanism set by the Ministry of Economy (Law 27.798, art. 38) (unconfirmed).

Reduced VAT rate on listed capital goods. Capital goods listed in the annex to art. 28(e) of the VAT Law are taxed at 10.5%, with refund of the resulting balance for manufacturers and importers (see VAT page (unconfirmed)).

Law 26.360 (history). Law 26.360 (sanctioned 12 March 2008, BO 9 April 2008) created a transitional regime of early VAT refund and accelerated depreciation for new capital goods for industry and infrastructure works, for projects between 1 October 2007 and 30 September 2010 (art. 2), later extended for infrastructure works with spending until 31 October 2018 and other deadlines by Laws 26.728, 26.784, 26.895, 27.008, 27.198 and 27.341 (Infoleg notes). It is closed to new projects, but its rules still govern renewables projects through Law 26.190, art. 9, and Law 27.191, art. 6(4), which keep Law 26.360 "in force" for that purpose.

No general accelerated depreciation in 2026. Outside RIGI, RIMI, mining, forestry and legacy renewables, depreciation follows the ordinary ITL rules (arts. 87 and 88 on movable goods; buildings under the ITL rules). The 2016 to 2018 SME scheme is closed (Law 27.264, art. 15).

6. Mining Investment Regime (Law 24.196)

Legal basis. Law 24.196 (sanctioned 28 April 1993, BO 24 May 1993), amended by Law 25.429 (BO 1 June 2001), Law 25.161 (BO 7 October 1999), Law 27.743 (BO 8 July 2024), Decree 593/2023 (BO 13 November 2023) and Decree 449/2025 (BO 7 July 2025), as shown in the Infoleg updated text.

Who. Individuals domiciled in Argentina and companies incorporated or authorised there that carry out mining activities on their own account (prospecting, exploration, development, extraction and integrated primary processing, art. 5), registered with the authority (art. 2). Service providers and public mining bodies get only the import exemption of art. 21. Excluded: hydrocarbons, cement, ceramics, and sand and gravel for construction (art. 6); persons with fraud convictions and those with final unpaid tax or social security debts (art. 3). The regime applies only in provinces that adhere by law and invite their municipalities to adhere (art. 4).

Benefits.

The "double deduction" of exploration costs. Art. 12 allows deduction of 100% of the amounts invested in exploration "without prejudice to the treatment that, as expense or amortisable investment, corresponds to them" under the ITL. Read literally, the cost is deducted twice: once under the special rule and once under ordinary rules. That is how the provision is usually described, and the worked example below applies it that way. The regulatory decree of Law 24.196 is not in the source files (unconfirmed).

Obligations. Annual sworn statement of works and investments within 30 days after the income tax return due date, with a report by an independent technical professional (art. 18, as replaced by Decree 449/2025); description of works and investment schedule (art. 25); geological data to SEGEMAR (art. 27).

Sanctions (arts. 28 and 29, as replaced by Decree 593/2023). Infringements: false sworn statements, failure to file or to provide information, refusal to show records, diversion of duty free goods. Penalties: fines from 10 to 200 minimum wages (salario mínimo, vital y móvil), suspension of the import benefit for 1 to 5 years, and loss of registration and benefits, without prejudice to tax, customs, FX and criminal penalties. The procedure is set by Secretariat of Mining Resolution 26/2021 (Infoleg note) (unconfirmed).

RIGI or Law 24.196? Large mines (USD 200,000,000 and over, with higher sector minimums for some subsectors) may choose RIGI. RIGI forbids stacking benefits of the same nature (Law 27.742, art. 208), so a VPU cannot claim both RIGI accelerated depreciation and the Law 24.196 accelerated depreciation for the same assets. Whether the Law 24.196 royalty cap and exploration deduction can coexist with RIGI as benefits "of a different nature" is not settled in the sources (unconfirmed).

7. Tierra del Fuego special regime (Law 19.640; Decree 727/2021)

Legal basis. Law 19.640 (16 May 1972; BO 2 June 1972 per Infoleg), as extended and regulated by Decrees 1139/1988, 479/1995, 490/2003, 1234/2007 and 727/2021 (signed 22 October 2021, BO 23 October 2021), with Decree 594/2023 (BO 14 November 2023) and Decree 111/2025 (BO 20 February 2025). The Infoleg file of Law 19.640 is the original text, not an updated text (unconfirmed).

Tax side. Persons, estates and companies are exempt from "every national tax" for acts, activities or operations carried out in the territory, or for goods located there (art. 1), with the exemption covering in particular the then existing income, sales and excise taxes and future national taxes (art. 4). Excluded: national taxes earmarked more than half to a specific purpose, service fees, and import and export duties (art. 3). For goods, the exemption applies only to goods located in or imported into the area (art. 2). The rest of the territory outside Isla Grande is a free area (art. 5) with no import or export taxes (arts. 6 and 7). How these exemptions apply to today's taxes (VAT, income tax, bank tax) depends on later law and regulation not held in the sources (unconfirmed).

Industrial promotion (Decree 727/2021).

• Term: rights and obligations of industrial companies with projects in force on 23 October 2021 extended to 31 December 2038; after 12 years, a further 15 years from 1 January 2039 if Brazil keeps the Manaus Free Zone regime, subject to compliance checks (art. 1). Approved projects that had not started activity lost the benefits (art. 2). For goods in Section XI of the Mercosur Common Nomenclature (textiles), the deadline was extended to 31 December 2028, extendable by the authority to 31 December 2033 (Decree 594/2023, Infoleg note).
• New projects: could be filed until 31 December 2023 for electronics and related technologies not already made in the province (art. 3). That window is closed (unconfirmed).
• FAMP contribution: companies had to contribute monthly 15% of the VAT benefit on promoted products to the Fondo para la Ampliación de la Matriz Productiva Fueguina (art. 4), with sanctions and loss of benefits after 90 days of non payment. Secretariat of Industry and Commerce Resolution 20/2026 (BO 21 January 2026) set the contribution at 0% for adhering companies "while the conditions that led to it subsist" (Infoleg note). Up to 40% of the contribution could be applied to the company's own approved projects (art. 6 bis, added by Decree 111/2025).
• Other rules: an additional 5% of FOB export refund for incremental exports to third countries, except listed tariff positions (art. 8); minimum production process to prove origin (art. 9); employment and social security compliance as a condition (art. 7); removal of VAT, excise and import duty benefits for goods listed in Annex II (art. 12); sanctions of Law 21.608, art. 17 (art. 13).

8. Renewable electricity (Laws 26.190, 27.191 and 27.828)

Law 26.190 (BO 2 January 2007) art. 9, as replaced by Law 27.191 (BO 21 October 2015), grants approved renewable generation projects: VAT early refund and accelerated depreciation under Law 26.360 (both together); loss carryforward extended to 10 years; exclusion of project assets from the minimum presumed income tax until the eighth year; deduction of project financing costs for the corporate capital loss rule; dividends reinvested in infrastructure outside the former 10% dividend tax; and a fiscal certificate of 20% of the national component of electromechanical installations if national content is at least 60% (or the proven lower share, not under 30%), transferable once and usable against income tax, VAT and excise.

The "second stage" (Law 27.191, art. 6) covers projects with start of execution between 1 January 2018 and 31 December 2025. VAT early refund applies after 2 periods (investments 2018 to 2021) or 3 periods (2022 to 2025). Accelerated depreciation: movable goods in at least 4 annual instalments (2018 to 2021) or 5 (2022 to 2025), works over 70% or 80% of useful life; investments from 1 January 2026 in projects that started before that date may still depreciate movable goods in at least 5 instalments.

Status for new projects. No provision in the sources extends the art. 6 tax benefits to projects starting execution after 31 December 2025. Law 27.828 (BO 13 October 2026) art. 6 extended only the art. 17 rule that renewable sources are not subject to specific taxes, levies or royalties, to 31 December 2045, and art. 7 allows assignment of supply contracts in exceptional cases. New renewable projects should look at RIGI (energy sector) or RIMI (high energy efficiency goods, no minimum) (unconfirmed).

9. Biofuels (Law 27.640)

Law 27.640 (BO 4 August 2021) replaced Laws 23.287, 26.093 and 26.334 (art. 21). The old Law 26.093 regime (VAT and income tax benefits under Law 25.924 for 15 years, art. 15) is gone. The current tax incentive is art. 22: biodiesel and bioethanol are not subject to the liquid fuels tax and the CO2 tax (Law 23.966, Title III), at all stages, and blends are taxed only on the fossil component, provided the main raw materials are national. The regime lasts until 31 December 2030, extendable once by five years by the Executive (art. 1).

10. Forestry (Law 25.080, as amended by Law 27.487)

Law 25.080 (BO 19 January 1999), substantially amended by Law 27.487 (BO 4 January 2019), applies to forest plantations and forest industry projects approved by the authority and registered (art. 24), in adhering provinces. Benefits: fiscal stability of up to 30 years from project approval, extendable to 50 by species and zone, excluding VAT (arts. 8 and 9, with stability certificates deemed accepted if not objected to within 20 business days); refund of VAT on goods and services for the forestry investment under the general art. 24 VAT refund rules, with the application period extended until clear cutting and sale (art. 10); accelerated depreciation of 60/20/20 for infrastructure and one third per year for machinery, capped at forestry taxable profit (art. 11); exemption from asset taxes on forest assets (art. 12); exemption from national taxes on incorporation, capital increases and securities of the project (art. 14); non refundable economic support for plantations (art. 17). Projects must be approved within the window of art. 25 (10 years from promulgation), extended by Law 26.432 and again by 10 years from expiry by Law 27.487, art. 17 (unconfirmed). Sanctions include loss of benefits, repayment and fines up to 30% of the investments made (art. 28).

11. Software (Law 25.922, historic)

Law 25.922 (BO 9 September 2004) gave software companies stability, a bond of up to 70% of contributions and a 60% income tax reduction (arts. 7 to 9, as amended by Law 26.692). It expired on 31 December 2019 (art. 1). Beneficiaries could migrate to the KE regime with registration deemed from 1 January 2020 (Law 27.506, art. 17), and unused Law 25.922 bonds remain valid until used (Law 27.506, art. 16).

12. Other national credits and incentives

13. Hydrocarbons

The source files contain no specific national tax incentive regime for oil and gas investments outside RIGI, which covers oil and gas, including new onshore developments since Decree 105/2026 (see the RIGI page). Mining Law 24.196 expressly excludes liquid and gaseous hydrocarbons (art. 6(a)). Whether any investment promotion benefits granted under the Hydrocarbons Law 17.319 or its regulations survive for new projects is not covered by the sources (unconfirmed). Law 27.828, art. 9 repealed Decree 277/2022 (unconfirmed). Export duties on crude oil are set by decree (see the customs page).

14. Provincial incentives: pointer table only

Most national regimes require or invite provincial adhesion, and provinces run their own gross income tax and stamp tax exemptions. No provincial incentive statute was available in the official sources for this page. The table lists only the adhesion hooks in national law; the provincial law numbers must be filled in by the editor.

How incentives interact

Stacking bans

Practical reading. The bans are per investment or per credit, not per company. A KE software company that buys servers may claim KE benefits on its income and, separately, either RIMI or the general VAT refund on the servers, but not both on the same VAT credits. A mining company under Law 24.196 that also buys irrigation equipment for an unrelated farm could, in principle, use RIMI for the farm equipment if it is a MiPyME, but the mining assets must stay under one regime. Whether ARCA reads "any other incentive regime" in art. 184(f) as covering the general VAT refund (which is not a promotion regime as such) is not settled (unconfirmed).

Fiscal stability compared

Mining stability is burden based: the company must prove, with separate accounting, that the total burden in a jurisdiction actually rose, offsetting increases against reductions in the same jurisdiction (Law 24.196, art. 8.5 and 8.7). Stability is therefore a claim to be documented, not an automatic shield.

Cost of losing benefits

Step by step

A. RIMI (micro, small or medium company buying capital goods)

1. Check size and certificate. Confirm the company is micro, small or medium up to tranche 2 and holds a valid MiPyME certificate on the first day of the month in which the fiscal year of the first investment starts (RGC 5849/2026, art. 2(a)). The certificate is requested online with Clave Fiscal (unconfirmed).
2. Check exclusions. No final unpaid tax, customs or social security debt; no relevant criminal convictions; the same investment is not under RIGI or another incentive (Law 27.802, art. 184).
3. Classify the goods. Confirm each asset is new, amortisable and classified BK or BIT in Decree 557/2023 Annex I (Decree 242/2026, art. 3), or appears in the SAGyP Resolution 75/2026 lists or the Secretariat of Energy list, or get a certified professional report (RGC 5849/2026, art. 3) (unconfirmed).
4. Track the minimum. Sum invoices net of VAT, converted at the Banco Nación buying rate of the business day before each invoice (Decree 242/2026, art. 7), until the minimum for the size is reached within the window.
5. Register investments in SGI. Load investments and select benefits in ARCA's "Sistema de Gestión de Inversiones (SGI)" (RGC 5849/2026, art. 1). For works in progress, upload invoices and the certified progress report (art. 4).
6. Notify the depreciation option to ARCA and apply it to all RIMI investments (Law 27.802, art. 182) (unconfirmed).
7. Request the VAT refund after three monthly periods from the period in which the credit arose (art. 183) (unconfirmed).
8. Keep the assets for two fiscal years after commissioning, or replace them with assets of equal or higher value (art. 186).

Cost to do it. No official fee found in the sources. Cost is mainly professional: a certified technical report where goods are not on the lists, and accounting work to track the USD minimum. Capital: the minimum investment itself (USD 150,000 to 9,000,000). Time: certificate and SGI registration typically weeks (unconfirmed); VAT refund at the earliest after three months, subject to the quota.

B. Knowledge Economy registration

1. Test eligibility on the last 12 months: 70% of revenue from promoted activities (Decree 1034/2020, Annex, art. 1) and at least two of the three additional requirements (Law 27.506, art. 4).
2. Gather evidence: certified accounting and technical documentation, quality certification or improvement evidence, training or R&D spend, export invoices (type "E"), union debt certificate or sworn statement (Annex, art. 2).
3. File the application with the enforcement authority, which decides with express mention of the promoted activities and their share of total activity (Annex, art. 5) (unconfirmed).
4. From the month after registration, the payroll bond accrues on contributions paid (Annex, art. 8); bonds appear in ARCA's service "Administración de Incentivos y Créditos Fiscales" (Annex, art. 9).
5. Apply the income tax reduction in the first fiscal year starting after registration (Law 27.506, art. 10).
6. Request the VAT non withholding certificate from ARCA if exporting (Annex, art. 11).
7. Report annually (headcount sworn statement, information regime) and revalidate every two years; pay the audit fee and FONPEC contribution.

Cost to do it. Audit fee up to 4% of benefits (art. 13); FONPEC 1% / 2.5% / 3.5% of benefits (Decree 1034/2020, Annex, art. 21); professional certification costs. Time to approval (unconfirmed).

C. Mining regime

1. Register with the Secretariat of Mining (Law 24.196, art. 2).
2. File the feasibility study; the date fixes the stability baseline; obtain the certificate (art. 10).
3. File the investment description and schedule (art. 25).
4. Notify the depreciation option to the authority and ARCA (art. 13.2).
5. Annual sworn statement with independent technical report within 30 days after the income tax return due date (art. 18).
6. Separate accounting for stability claims (art. 8.5.1).

Cost to do it. No official fee in the sources (unconfirmed). Independent technical report each year. Time (unconfirmed).

D. SME bank tax credit

1. Obtain and keep the MiPyME certificate.
2. Compute the bank tax effectively paid during the year (Law 27.264, art. 6).
3. Credit 100% (micro, small) or 60% (medium T1 manufacturer) against income tax advances or the annual return; reduce advances if the credit plus advances exceed the estimated tax.
4. Do not deduct the credited amount as an expense.

Costs and timelines

Rates and benefit levels

Thresholds

Deadlines and sunsets

2026 budget quotas for incentives (Law 27.798, BO 2 January 2026)

Timeline of norms (BO dates)

Worked examples

Example 1: a small knowledge economy company, fiscal year 2026

Facts. A software company (SRL) with a valid MiPyME certificate as a small company, registered in the KE regime before the start of fiscal year 2026, 100% of its revenue from promoted activities. Exports are 40% of revenue. Taxable income for 2026: ARS 600,000,000 (US$ 383,656.24). Gross payroll of staff assigned to promoted activities: ARS 900,000,000 (US$ 575,484.37). The employer pays the 18% unified rate (Law 27.541, art. 19(b)), ignoring for simplicity the fixed monthly deductions of Law 27.541, arts. 22 and 23, and the separate health insurance contribution (not covered by the bond). No new hires qualify for the 80% rate.

Step 1: income tax without the regime (ARCA 2026 scale, second bracket):

ARS 33,378,546.43 + 30% × (600,000,000 − 133,514,185.74) = 33,378,546.43 + 139,945,744.28 = ARS 173,324,290.71 (US$ 110,828.24).

Step 2: KE income tax reduction (Law 27.506, art. 10, 60% for small):

60% × 173,324,290.71 = ARS 103,994,574.42 (US$ 66,496.95). Income tax after reduction: ARS 69,329,716.28 (US$ 44,331.30).

Step 3: payroll contribution bond (art. 8; Decree 1034/2020, Annex, art. 8):

Contributions to SIPA, PAMI, employment fund and family allowances: 18% × 900,000,000 = ARS 162,000,000 (US$ 103,587.19). Bond: 70% × 162,000,000 = ARS 113,400,000 (US$ 72,511.03).

Step 4: use of the bond. Because the company exports, it may use the bond against income tax up to its export percentage (art. 8, fourth paragraph). Reading that as 40% of the bond: ARS 45,360,000 (US$ 29,004.41) against income tax, leaving cash income tax of ARS 23,969,716.28 (US$ 15,326.89). The remaining ARS 68,040,000 (US$ 43,506.62) is used against VAT and other national taxes within 24 months (unconfirmed).

Step 5: costs of the regime. FONPEC at 2.5% of total benefits (103,994,574.42 + 113,400,000): ARS 5,434,864.36 (US$ 3,475.20). The audit fee of up to 4% is left out because its actual rate is not in the sources (unconfirmed).

Result.

The saving is about 23.6% of payroll. Three cautions: contributions must first be paid before the bond accrues, so the company prefinances them; the bond depends on the annual quota (ARS 310,000,000,000 in 2026); and a headcount drop not made good within 60 days ends all benefits automatically (art. 15 bis).

Example 2: a medium sized mine under Law 24.196, three years with and without the regime

Facts. An Argentine mining company already producing in an adhering province expands. In year 1 it spends ARS 1,500,000,000 (US$ 959,140.61) on exploration and feasibility work and puts into service machinery and equipment costing ARS 6,000,000,000 (US$ 3,836,562.44). Profit before exploration and depreciation: ARS 4,000,000,000 in year 1 and ARS 5,000,000,000 in years 2 and 3. Assumptions for simplicity: the 2026 CIT scale applies to all three years (in reality the brackets are updated each year); no tax inflation adjustment; machinery useful life of 10 years for the general regime (unconfirmed); exploration deductible as an expense in year 1 under the general regime (unconfirmed).

General regime. Depreciation: 6,000,000,000 / 10 = 600,000,000 per year.

Mining regime (Law 24.196, arts. 12 and 13).

• Exploration: 1,500,000,000 ordinary deduction plus 1,500,000,000 under art. 12 = 3,000,000,000 in year 1.
• Machinery: one third per year, 2,000,000,000, capped at mining profit before depreciation (art. 13.3(a)), excess carried forward (art. 13.3(b)).

(Year 2 tax: 393,866,847.93 + 35% × (2,000,000,000 − 1,335,141,857.38) = 626,567,197.85. Year 3: 393,866,847.93 + 35% × (3,000,000,000 − 1,335,141,857.38) = 976,567,197.85.)

Difference over three years: ARS 1,921,567,197.85 (US$ 1,228,702.09) less tax. Most of it is timing: under the general regime ARS 4,200,000,000 of machinery cost is still to be depreciated in years 4 to 10, worth up to about ARS 1,470,000,000 (US$ 939,957.80) at 35%. The permanent gain is the extra exploration deduction, worth about ARS 525,000,000 (US$ 335,699.21) at 35%, plus stability, the import duty exemption on the machinery (not quantified here) and the royalty cap. Against this, the company bears the annual independent technical report and the risk of sanctions for diverting duty free equipment (art. 28(e)).

Example 3: a small manufacturer using RIMI for a USD 700,000 machine

Facts. A small company (valid certificate) imports a new CNC machine classified BK, invoiced USD 700,000, put into service in July 2026. At the MEP rate that is about ARS 1,094,730,000; for the RIMI minimum the company must convert at the Banco Nación buying rate of the day before the invoice (Decree 242/2026, art. 7), so the peso cost in its books will differ. USD 700,000 exceeds the small company minimum of USD 600,000. Assume the machine is on the reduced VAT rate list (10.5%) (unconfirmed), 10 year useful life and a 30% marginal income tax rate.

• VAT. Credit 10.5% × 1,094,730,000 = ARS 114,946,650 (US$ 73,500). Under RIMI, if still unabsorbed, refundable after three monthly periods (art. 183) instead of six, subject to the RIMI half of the ARS 30,000,000,000 national cap.
• Depreciation. RIMI: two instalments of ARS 547,365,000 (US$ 350,000) in 2026 and 2027. General: ARS 109,473,000 (US$ 70,000) per year. Extra deduction in each of the first two years: ARS 437,892,000 (US$ 280,000), worth ARS 131,367,600 (US$ 84,000) of income tax deferred per year at 30%.
• Trap. If the company sells the machine before the end of the second fiscal year after start up without replacing it, it loses both benefits and faces a fine of up to twice the benefit (arts. 186 and 187).

Practical traps

• "Same investment" means each asset and each VAT credit. Plan which regime each asset goes under before invoicing. RIMI excludes investments benefiting from any other incentive regime (Law 27.802, art. 184(f)); the general VAT refund excludes credits that got any other special treatment.
• The MiPyME certificate date. RIMI looks at the certificate on the first day of the month in which the fiscal year starts (RGC 5849/2026, art. 2(a)). A company that grows past tranche 2 or forgets to renew loses RIMI for the year.
• RIMI window uncertainty. The decree window (to about 19 May 2028) is longer than the statutory two years from 6 March 2026. Invoice and commission before 6 March 2028 if possible.
• RIMI uses the official rate for the minimum. Using MEP or CCL figures to test the USD minimum will overstate or understate it; use the Banco Nación buying rate per invoice.
• Quotas, not entitlements. KE bonds, the general VAT refund and the RIMI VAT refund all depend on annual budget amounts. A valid claim may still wait.
• KE headcount rule. Any reduction in headcount assigned to promoted activities not made good within 60 days ends the benefits automatically (Law 27.506, art. 15 bis; Decree 1034/2020, Annex, art. 7). Group restructurings that move staff between entities need the reorganisation notice of Annex art. 14 within 30 business days.
• KE in house development. Development for the company itself or for related companies does not count toward the 70% threshold (art. 5). Captive service centres for a foreign group may still qualify if they invoice the group for services, but "own use" structures do not (unconfirmed).
• KE bond is not cash. It is non refundable and expires after 24 months (plus 12). Companies with little VAT payable (exporters) may not be able to use it; transfer is only allowed if exports reach 70% (art. 8).
• Mining stability is not VAT or payroll. Expect VAT and social security changes to apply (Law 24.196, arts. 8.4.5 and 9).
• Mining depreciation cap. Accelerated depreciation cannot create a loss (art. 13.3(a)); the excess is carried forward, which helps only if the mine is profitable later.
• Duty free equipment stays put. Equipment imported under Law 24.196 art. 21 cannot be sold or diverted to non mining use before the end of the activity cycle or its useful life without paying duties.
• Legacy regimes in due diligence. Targets that used Law 27.264 Title III (2016 to 2018), Law 26.360 or renewables benefits may still face clawback if employment fell or assets were sold early. Ask for the beneficiary files.
• Tierra del Fuego is not a general tax haven. The 1972 exemptions apply to activities and goods in the territory; import and export duties and earmarked taxes are excluded (Law 19.640, art. 3), and industrial benefits depend on approved projects and compliance (Decree 727/2021).
• Renewables after 2025. A new solar or wind project starting in 2026 does not get Law 27.191 VAT and depreciation benefits on the texts in the sources; only the no specific taxes rule (to 2045) applies.
• Stacking with RIGI. A RIGI VPU cannot also claim RIMI for the same assets and cannot double up incentives of the same nature (Law 27.742, art. 208).

Recent changes

• 13 October 2026. Law 27.828. Extends to 31 December 2045 the rule that renewable energy sources are not subject to specific taxes, levies or royalties (Law 27.191, art. 17); allows exceptional assignment of renewables supply contracts (art. 7); repeals Decree 277/2022 (art. 9).
• 4 September 2026. Decree 868/2026. RIGI amendments (sworn statement on Law 26.659 conduct; see RIGI page).
• 8 June 2026. SAGyP Resolution 75/2026. Lists of irrigation equipment, anti hail nets and breeding animals that qualify for RIMI without a minimum.
• 19 May 2026. RGC 5849/2026. RIMI procedure: SGI web service, certificate timing, non profit eligibility, proof of works progress, control and sanctions.
• 13 April 2026. Decree 242/2026. RIMI regulation: window, BK and BIT goods, works under 30% complete, USD conversion rule, 50% of the VAT refund cap.
• 6 March 2026. Law 27.802. Creates RIMI (Title XXIII) and the RIFL new hire contribution cut (Title XX); CPI indexation of tax losses from fiscal years starting 2025 (art. 190).
• 19 February 2026. Decree 105/2026. RIGI adhesion deadline extended once by one year.
• 21 January 2026. SIC Resolution 20/2026. FAMP contribution of Tierra del Fuego industrial companies set at 0%.
• 2 January 2026. Law 27.798 (2026 Budget). Quotas: KE ARS 310,000,000,000; VAT refund ARS 30,000,000,000; training ARS 8,355,000,000; biotech ARS 2,000,000,000; automotive ARS 5,000,000,000.
• 7 July 2025. Decree 449/2025. Mining regime: stability certificate (art. 10), annual sworn statement with independent technical report (art. 18), verification (art. 26), geological data (art. 27).
• 20 February 2025. Decree 111/2025. FAMP distribution 60/40 and own project option.
• 8 July 2024. Laws 27.742 and 27.743. RIGI; mining royalties up to 5% for new projects in provinces adhering to the new text.

Pending changes

1. RIMI closing date: statutory two years from 6 March 2026 versus decree two years from 19 May 2026. Guidance needed.
2. Secretariat of Energy list of high energy efficiency goods for RIMI (RGC 5849/2026, art. 3) not found in the sources.
3. Ministry of Economy list of capital goods and works under Law 27.802, art. 182, last paragraph, if issued.
4. 2026 allocation mechanism for the ARS 30,000,000,000 VAT refund cap and for the RIMI 50% share.
5. KE audit fee rate (art. 13) and any change in the enforcement authority after 2024.
6. KE after 2029: no rule on extension or on unused bonds.
7. Renewables: no extension of tax benefits for projects starting after 2025.
8. Forestry window end date after Law 27.487.
9. Hydrocarbons: whether any national investment promotion benefits under Law 17.319 regulations remain for new projects.
10. Provincial adhesion laws for mining, forestry, KE and RIGI.
11. Mining and RIGI coexistence: which Law 24.196 benefits are "of a different nature".

FAQ

1. I am a foreign company setting up a software subsidiary. Which incentive matters most? The Knowledge Economy Regime. Once registered, the subsidiary can reduce income tax on promoted activities by 60%, 40% or 20% depending on size and get a bond of 70% of employer contributions (Law 27.506, arts. 8 and 10). It must meet the 70% revenue test and two of three additional requirements (art. 4), and work for related companies for their own use does not count (art. 5).

2. Can a newly formed company join the KE regime? Yes. A micro company under three years old only needs to show that promoted activities are its main activity (art. 6). Other companies without revenue may apply by proving intensive development of promoted activities (art. 4.II(b)).

3. Is there an incentive for an SME buying machinery in 2026? Yes: RIMI, if the company holds a MiPyME certificate up to tranche 2 and reaches the minimum investment for its size (USD 150,000 to 9,000,000), or invests in irrigation, energy efficiency, anti hail nets or breeding animals with no minimum (Law 27.802, arts. 179 to 181). Otherwise, the general VAT refund after six periods applies to any taxpayer (VAT Law, art. 24, first unnumbered article).

4. Can I combine RIMI with the knowledge economy regime? Not for the same productive investments if the authority treats the KE regime as "any other incentive regime" (Law 27.802, art. 184(f)). The KE benefits concern income tax on activities and payroll, while RIMI concerns specific assets, so a KE company could argue they do not overlap. The text does not settle this (unconfirmed).

5. Does RIGI replace the mining law? No. Law 24.196 remains in force with no sunset. Large mining projects may choose RIGI, but they cannot add up incentives of the same nature from both (Law 27.742, art. 208).

6. What is the royalty cap for a new mine? 3% of the pithead value under Law 24.196, art. 22, but up to 5% for projects that had not started construction of the exploitation stage when Law 27.743 came into force (8 July 2024), in provinces that adhere to the new text.

7. What happens if a KE company lays off staff? If headcount assigned to promoted activities drops and is not restored within 60 days, the benefits fall automatically (Law 27.506, art. 15 bis; Decree 1034/2020, Annex, art. 7). Resignations, dismissal for cause, retirement and end of a fixed term do not count as reductions.

8. Does fiscal stability protect me from VAT increases? No. Mining stability excludes VAT and social security (Law 24.196, arts. 8.4.5 and 9), forestry stability excludes VAT (Law 25.080, art. 8), and RIGI stability excludes VAT rate increases and social security (Law 27.742, art. 202).

9. Is Tierra del Fuego still open for new factories? The Decree 727/2021 window for new electronics projects closed on 31 December 2023 (art. 3). Existing approved projects run to 31 December 2038, with a possible 15 year extension (art. 1). The general exemption of Law 19.640 for activities in the territory remains, subject to its exclusions (unconfirmed).

10. Can my SME still use the 2016 investment payment on account? No. Law 27.264 Title III applied to investments between 1 July 2016 and 31 December 2018 (art. 15). The bank tax credit (art. 6) and VAT deferral (art. 7) remain.

11. How much can a medium manufacturer credit of the bank tax against income tax? 60% of the bank debit and credit tax actually paid if it is a medium tranche 1 manufacturing company (Law 27.264, art. 6; Decree 409/2018). Micro and small companies credit 100%. RIGI VPUs credit 100% (Law 27.742, art. 189).

12. Are KE bonds taxable income? No. The bond and the art. 9 bonus are not computable for net income (Law 27.506, art. 8).

13. My renewables project starts construction in 2026. Do I get the VAT early refund? Not under Law 27.191 on the texts in the sources: the second stage covers projects with start of execution up to 31 December 2025 (art. 6). Consider RIGI if the size fits, or RIMI for eligible energy efficiency goods if the company is a MiPyME.

Primary sources

• Decree 242/2026 (RIMI regulation), BO 13 April 2026). Infoleg record
• Infoleg list of norms complementing Law 27.802 (consulted 25 October 2026)
• Infoleg list of norms complementing Law 27.506 (consulted 25 October 2026)

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