Argentina's Congress turned the 'Fiscal Innocence' bill into law on December 26, introducing tax system reforms that simplify declarations and update penalties. The measure aims to normalize patrimonial situations and draw undeclared savings into the formal economy. Critics view it as a disguised money laundering scheme, while supporters praise it for reducing fiscal persecution.
The Fiscal Innocence Law, approved on Friday, December 26, 2025, reforms the Tax Penal Regime, Procedure Tax Law No. 11.683, and the Civil and Commercial Code on prescription matters. It introduces the Simplified Sworn Declaration Regime (DSIG) for resident individuals, allowing Ganancias tax declarations based solely on invoicing, regardless of patrimonial variations.
To join DSIG, taxpayers must have total income up to one billion pesos and assets up to ten billion pesos as of December 31 of the previous year, and not be classified as a major national contributor by ARCA. The law presumes the accuracy of Ganancias and IVA declarations, except for significant discrepancies, such as adjustments over 15% or amounts exceeding evasion thresholds.
It updates penal thresholds: simple evasion rises from 1.5 million to 100 million pesos, and aggravated from 15 million to 1,000 million. It shortens the prescription period to three years for timely declarations without discrepancies. It modifies fines, raising penalties for non-filing from 200-400 pesos to 220,000-440,000 pesos, though without a uniform criterion.
President Javier Milei described it as 'a money laundering without tax payment', with non-revenue purposes, to shield 'good Argentines' and attract dollars from the 'mattress'. Juan Pazo, former ARCA head, defended it as the end of a 'Soviet regime' of persecution, focusing on simplifying controls and ensuring freedom in using savings, facilitating credit access and reducing tax pressure by over 2.5 PBI points.
Juan Manuel Álvarez Echagüe, UBA professor, criticizes the law as an 'indirect money laundering' without amnesty, inviting undeclared income by ignoring patrimonial consumption, creating legal uncertainty. The norm also exempts adherents from reporting assets and limits penal complaints if obligations are paid before filing.
