The norm, in detail
Fiscal Innocence: less prison exposure and less tax-agency pressure for the compliant
Ley 27.799
in forceNATIONAL
Fiscal and monetary anchor
Ley 27.799 raises the simple evasion threshold from $1.5 M to $100 M and the aggravated one to $1,000 M, and creates a simplified income tax return.
What changed and who it applies to
What changed
It reforms the Criminal Tax Regime and Ley 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 ↗
Are you in or out?
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
No effect lands differently in any one province: it applies the same across the country.
What it leads to1
Inocencia Fiscal II: the caps go, and ARCA needs a large gap to challenge a returnExecutive branch bill · passed the lower house Aug 26, 2026pending
The other rules on this subject22
Fiscal Package: asset amnesty, moratorium and tax cutsLey 27.743 (Official Gazette Jul 8, 2024)in force
Fiscal anchor: surplus two years in a rowExecutive execution policy on the extended budget (Decreto 1131/2024)in force
Payment to holdouts: closing the 2001-default lawsuitsLey 27.818 (promulgated by Decreto 564/2026, Official Gazette Jul 1, 2026)in force
The "lock on the State": fiscal balance by lawLey 27.798 (2026 Budget), art. 1 — in force; the permanent "lock on the State" still a billpending
PAÍS Tax: it rose, fell and expiredDecreto 29/2023 + Decreto 777/2024 (expiry of Ley 27.541, 12/23/2024)in execution
Renting out and selling housing no longer pays income taxLey 27.802 Title XXIV + Decreto 406/2026 (Official Gazette Jun 1, 2026)in force
Ignacio Aredez· Chief analyst
Credentials and track record →- 10+ years in data science for clients across Europe and the Americas
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How to read the seals → verif primary source · prob primary source pending · unconf a source said it · estim our own calculation · thesis our reading · the date belongs to the datum, at the precision its source allows
Fact sheet built on the published rule, with the gaps declared. Back to the reforms
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