The norm, in detail
Fiscal Innocence: less prison exposure and less tax-agency pressure for the compliant
Law 27.799
in forceNATIONAL
Fiscal and monetary anchor
What changed and who it applies to
What changed
It reforms the Criminal Tax Regime and Law 11.683. (1) It raises the criminal floors: simple evasion from $1,500,000 to $100,000,000 and aggravated evasion from $15,000,000 to $1,000,000,000, with annual UVA adjustment from 2027. (2) It creates an optional Simplified Income-Tax sworn-statement regime for natural persons (income <= $1,000,000,000 and net worth <= $10,000,000,000) with full releasing effect for the period's tax, a presumption of accuracy and a limit on ARCA audits except for significant discrepancy. (3) It adds extinction of criminal action by payment (debt + interest + 50%, within 30 business days after being charged, once only) and reduces from 5 to 3 years the statute of limitations for compliant taxpayers in national taxes. The OFFICIAL title in the Official Gazette is 'Criminal Tax Regime'; 'Fiscal Innocence' is the popular/professional name. verif · Jan 2, 2026 ↗
In force
Jan 2, 2026: the law 'will take effect on the day of its publication' in the Official Gazette. It does not depend on subsequent regulation (a regulatory decree reported for Feb-2026, unconfirmed in the primary source). verif · Jan 2, 2026 ↗
Who it affects
Natural and legal persons with tax obligations, social-security contributors and withholding/collection agents. The Simplified sworn-statement regime specifically targets natural persons and undivided estates with income <= $1,000,000,000 and net worth <= $10,000,000,000. verif · Jan 2, 2026 ↗
The norm
Ley 27.799, passed on Dec 26, 2025, enacted and published in the Boletín Oficial on Jan 2, 2026 (notice 337029). Official title: 'Régimen Penal Tributario' (criminal tax regime). verif · Jan 2, 2026 ↗
Our reading
The State raises the bar for criminal prosecution and gives the compliant taxpayer a simple path with releasing effect and less auditing: less criminal risk and less friction to declare (R4 deregulation, R5 lower effective burden). In the bullish reading, it lowers the cost of coming clean and operating by the book, which tends to formalize savings today outside the system. What we watch: that the regulation and ARCA follow the law's spirit and do not reintroduce friction through the window. thesis
Where it lands, province by province
Applies the same nationwide
We looked at this rule from each of the five provinces we track and found no effect that lands differently in any of them: it applies the same across the country.
The other rules on this subject19
Fiscal Package: asset declaration, moratorium and tax cutsLaw 27.743 (Official Gazette Jul 8, 2024)in force
Fiscal anchor: surplus two years in a rowExecutive execution policy on the extended budget (Decree 1131/2024)in force
Payment to holdouts: closing the 2001-default lawsuitsLaw 27.818 (promulgated by Decree 564/2026, Official Gazette Jul 1, 2026)in force
The "lock on the State": fiscal balance by lawLaw 27.798 (2026 Budget), art. 1 — in force; the permanent "lock on the State" still a billpending
PAÍS Tax: it rose, fell and expiredDecree 29/2023 + Decree 777/2024 (expiry of Law 27.541, 12/23/2024)in execution
Renting out and selling housing no longer pays income taxLaw 27,802 Title XXIV + Decree 406/2026 (Official Gazette Jun 1, 2026)in force
Ignacio Aredez· Chief analyst
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Fact sheet built on the published rule, with the gaps declared. Back to the reforms
How to read the seals → verif primary source · prob primary source pending · unconf not sufficiently backed · estim our own calculation · thesis our reading