Executive summary

A bill that the Argentine Executive Branch sent Congress on 5 June 2025 seeks, in part, to achieve three main objectives: (1) reduce the tax compliance burden by simplifying tax assessment and auditing procedures; (2) rationalize the current criminal tax regulations to proportionately penalize behaviors that could damage the public administration and social security systems; and (3) reduce the statute of limitations for challenging a filed tax return to provide greater certainty and predictability to the fiscal system.

The main measures included in the bill are highlighted below.

Reform to the Tax Procedure Law

The bill proposes to increase penalty amounts.

The statute of limitations for challenging a taxpayer’s return generally would be reduced from five to three years, if (1) the registered taxpayer has timely filed the corresponding tax return and paid any resulting balance, and (2) the challenge does not involve a significant discrepancy between the information declared on the return and the information available in the tax authorities’ systems or provided by third parties.

The requirements that must be verified to determine if there is a significant discrepancy are established under the bill.

Reform to the Criminal Tax Regime

The bill proposes, among other things, to increase the thresholds for tax crimes.

Other changes

The bill also introduces reforms to the Argentine Civil and Commercial Code, as well as a Simplified Return Regime for certain individuals who reside in the country. Further, the bill seeks cooperation from the Argentine provinces and the City of Buenos Aires, encouraging them to implement more efficient control regimes.

Implications

It is expected that the bill will contribute to a less-contentious tax environment, with a lower level of litigation. In addition, simplification of the audit processes will help reduce the compliance burden.

Finally, the proposed reform seeks to generate a fairer and more-efficient criminal tax system, focused on proportionate and targeted penalties to counter behaviors that damage to public administration and social security systems.

Entities doing business in Argentia should monitor the bill’s progress.