{"id":15168,"date":"2026-06-04T12:18:34","date_gmt":"2026-06-04T15:18:34","guid":{"rendered":"https:\/\/ar.andersen.com\/historic-tax-relief-details-of-caputos-project-to-massify-the-simplified-income-tax-regime-iprofesional-press\/"},"modified":"2026-06-04T14:52:36","modified_gmt":"2026-06-04T17:52:36","slug":"historic-tax-relief-details-of-caputos-project-to-massify-the-simplified-income-tax-regime-iprofesional-press","status":"publish","type":"post","link":"https:\/\/ar.andersen.com\/en\/historic-tax-relief-details-of-caputos-project-to-massify-the-simplified-income-tax-regime-iprofesional-press\/","title":{"rendered":"Historic tax relief: details of Caputo’s project to massify the Simplified Income Tax Regime | IProfesional Press"},"content":{"rendered":"\n

F\u00e9lix Rolando<\/strong> analyzes the scope of the project that would modify the Simplified Income Tax Regime and highlights that, with the new law, only large national taxpayers would be excluded.<\/p>\n\n

We reproduce below the complete article published by iProfesional<\/em>:<\/p>\n\n

\n\n

<\/p>\n\n

The Minister of Economy, Luis Caputo, is preparing a corrective law of the Fiscal Innocence to modify the Simplified Income Tax Regime, which will allow almost all taxpayers to enter the regime, eliminating the barriers that exist today, together with the dangers that cause the benefits to fall.<\/strong><\/p>\n\n

The main aspects that the new project<\/strong> on the Simplified Income Tax Regime would contain have<\/strong> to do with the following two points, agree F\u00e9lix Rolando, from Andersen Argentina, and C\u00e9sar Litvin, from LLA:<\/p>\n\n

Who will be able to join the Simplified Income Tax System<\/h2>\n\n

The Simplified Income Tax regime is a new filing modality for tax returns that applies only to resident individuals and undivided estates, and will continue to be restricted only to those who are large national taxpayers.<\/p>\n\n

Until now, it is also added that taxpayers with income exceeding $1,000 million and assets exceeding $10,000 million valued according to the Personal Property Tax rules may not adhere, but this condition will cease to apply.<\/p>\n\n

But with the new project, many more taxpayers will be able to enter Simplified Income Tax, since the asset and income limit will be eliminated<\/strong>, thus allowing a large number of taxpayers to enter, regardless of their income or assets, experts agree.<\/p>\n\n

“With the new law, only large national taxpayers would be excluded,” Rolando points out.<\/strong><\/p>\n\n

“This modification would result in a better compliance with the principle of equality, by not establishing thresholds and discriminations among taxpayers,” he believes.<\/strong><\/p>\n\n

However, the new regime does not change any Income Tax rules, but simplifies the filing by not requiring the reporting of net worth or the determination of the amount consumed, while simplifying the burden by requesting less information regarding assets and securities within each category.<\/p>\n\n

When can it be kept in force now<\/h2>\n\n

The fall of the regime for a significant difference or discrepancy would be eliminated<\/strong>. In case of a base year (2025) audit, if the difference is accepted and paid, the prohibition for ARCA to review 2022, 2023 and 2024 would be maintained, experts explain. <\/p>\n\n

In this regard, the date on which the benefit falls if the taxpayer disputes a technical criterion remains under discussion, says an unnamed source.<\/p>\n\n

The accountants ask that, in the event of a technical difference that the taxpayer disputes in court, the release of the years not prescribed can only occur when there is a final judgment (of the Supreme Court of Justice), he says.<\/p>\n\n

This request of the experts is based on what already happened with a “tax plug” offered by a “blanqueo” that was put into effect by the former Minister of Economy Domingo Cavallo, which in many cases was discussed in the Justice, and the taxpayers won in the Supreme Court of Justice, but they had already been audited without the blockade, he argues.<\/p>\n\n

When there is a significant discrepancy today<\/h2>\n\n

ARCA presumes that the simplified return is correct and does not revise backwards<\/strong> unless it detects a significant discrepancy in the base period being reported. The regulations establish three objective parameters for a discrepancy to qualify as such: <\/p>\n\n

The percentage parameter (15%)<\/strong>: when the audit detects an omission of income or the computation of improper deductions that generate an increase of the tax in favor of the tax authorities (or a reduction of losses or balances in favor) equal to or higher than 15% with respect to what was declared by the taxpayer.<\/p>\n\n

The penal parameter ($100 million)<\/strong>: when the nominal difference detected exceeds the threshold of simple tax evasion foreseen in the Criminal Tax Regime, currently set at $100 million.<\/p>\n\n

Apocryphal invoices<\/strong>: the use of apocryphal vouchers or invoices that alter the balance in favor of the tax authorities or reduce tax losses.<\/p>\n\n

What changes with the new law<\/h2>\n\n

Today, the fall of the Simplified Income Tax Regime is automatic in case of a difference of 15% or $100 million<\/strong> in the declaration of the base year (2025).<\/p>\n\n

However, if apocryphal invoices<\/strong> appear , the taxpayer may rectify the return<\/strong> and pay the difference with interest before the agency’s challenge, and does not lose the benefits.<\/p>\n\n

With the new law, the Simplified Income Taxpayer will be able to make this rectification in any of the three cases <\/strong>of significant difference.<\/p>\n\n

What are the consequences of the significant difference<\/h2>\n\n

The key benefits of this regime are the “dischargeability” of the base year payment and the “presumption of accuracy” that shields prior years. If ARCA breaks that presumption by demonstrating a significant difference, the consequences are as follows: <\/p>\n\n

Loss of the presumption of accuracy<\/strong>: the legal shield falls. ARCA is fully empowered to deploy its verification and control powers. <\/p>\n\n

Extension to non-prescribed periods<\/strong>: ARCA recovers the power to review, determine ex officio and demand debts for all previous tax periods that have not prescribed, both in Income Tax and VAT.<\/p>\n\n

Fall of the benefit of capital gains<\/strong>: when the regime falls, the taxpayer loses the exemption of not justifying the origin of the funds or tax movements of those years, reactivating the traditional methods of presumption of capital gains (such as unjustified capital gains).<\/p>\n\n

Application of penalties<\/strong>: in addition to the collection of tax differences with compensatory and punitive interest, fines for omission or fraud as provided for in the Tax Procedure Law are applied and, if appropriate for the amounts involved, the respective criminal actions are applied.<\/p>\n\n

In short, the appearance of a significant difference operates as a trigger that completely disarticulates the benefit of stability and definitive closure offered by Simplified Profits, returning the taxpayer to the general regime of integral and retroactive auditing, and this danger is what strongly diminishes with the new law.<\/p>\n\n

Source: Iprofesional.com<\/a><\/p>\n\n

If you have any questions about this topic, please do not hesitate to contact us:<\/strong><\/p>\n\n

F\u00e9lix Rolando<\/strong>Tax Partnerfelix.rolando@ar.Andersen.com<\/a><\/p>\n","protected":false},"excerpt":{"rendered":"

F\u00e9lix Rolando analyzes the scope of the project that would modify the Simplified Income Tax Regime and highlights that, with the new law, only large national taxpayers would be excluded. We reproduce below the complete article published by iProfesional: The Minister of Economy, Luis Caputo, is preparing a corrective law of the Fiscal Innocence to […]<\/p>\n","protected":false},"author":16,"featured_media":15166,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"_acf_changed":false,"_joinchat":[],"footnotes":""},"categories":[96,93],"tags":[],"class_list":["post-15168","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-tax-en","category-press-en"],"acf":[],"_links":{"self":[{"href":"https:\/\/ar.andersen.com\/en\/wp-json\/wp\/v2\/posts\/15168","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/ar.andersen.com\/en\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/ar.andersen.com\/en\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/ar.andersen.com\/en\/wp-json\/wp\/v2\/users\/16"}],"replies":[{"embeddable":true,"href":"https:\/\/ar.andersen.com\/en\/wp-json\/wp\/v2\/comments?post=15168"}],"version-history":[{"count":2,"href":"https:\/\/ar.andersen.com\/en\/wp-json\/wp\/v2\/posts\/15168\/revisions"}],"predecessor-version":[{"id":15171,"href":"https:\/\/ar.andersen.com\/en\/wp-json\/wp\/v2\/posts\/15168\/revisions\/15171"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/ar.andersen.com\/en\/wp-json\/wp\/v2\/media\/15166"}],"wp:attachment":[{"href":"https:\/\/ar.andersen.com\/en\/wp-json\/wp\/v2\/media?parent=15168"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/ar.andersen.com\/en\/wp-json\/wp\/v2\/categories?post=15168"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/ar.andersen.com\/en\/wp-json\/wp\/v2\/tags?post=15168"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}