On 17 September 2026, Argentina's Senate passed the law that everyone in Buenos Aires simply calls "Inocencia Fiscal II". By 44 votes to 23, the chamber turned the Milei government's bill into law, according to the Senate's announcement. The Chamber of Deputies had approved it at the end of August by 139 votes to 110 with two abstentions, reports the Cámara de Diputados.
On 9 October 2026 it was published in the Boletín Oficial as Law 27,826, promulgated by Decree 1160/2026. Under its Article 19 it takes effect on the day of publication, so it has applied since 9 October 2026.
If you are moving to Argentina, this is not just a topic for tax advisers. It is about how the Argentine tax authority treats you once you are tax resident there, and at one point the law draws a new line that hits newcomers in particular.
Why this affects you as a new resident
Argentina taxes its residents on their worldwide income. That is what Article 1 of the Income Tax Law (Ley de Impuesto a las Ganancias) says: anyone resident in the country pays tax on profits from Argentina and abroad and can credit foreign taxes up to the amount of the additional Argentine tax. Non-residents pay only on Argentine-source income.
When you become resident as a foreigner is governed by Article 116 of the same law. There are two routes: either you hold permanent residence, or you live in the country for twelve months on a temporary residence permit. Short absences do not interrupt this period, as set out in the implementing regulation. If you do not have permanent residence and are in the country only for reasons that show no intention to stay permanently, you can provide evidence to that effect.
In practice: whether you start with temporary or permanent residence, after twelve months in the country at the latest you are, as a rule, in the tax net too. The available residence permits are covered in our overview of residency in Argentina. And once you are in, you deal with exactly the regime that Inocencia Fiscal II is now rebuilding.
What Inocencia Fiscal I introduced
The first part is Law 27,799, passed by Congress on 26 December 2025 and published in the Boletín Oficial on 2 January 2026. It did two things that matter for individuals.
First, it raised the criminal threshold for simple tax evasion under tax criminal law from 1.5 million to 100 million pesos. Second, it created a simplified income tax return: the tax authority ARCA proposes a return, you accept it and pay on time. Your income tax for that year is then settled, with "efecto liberatorio", a discharging effect. On top of that comes a presumption of accuracy for your income tax and VAT returns for the years not yet time-barred. ARCA can only rebut this presumption if it proves a "discrepancia significativa", a significant discrepancy between your figures and what is in its systems or held by third parties.
The catch in the first version: access was limited to people whose revenue in the two previous years was under 1,000 million pesos and whose assets were under 10,000 million pesos, counting assets in Argentina and abroad. Anyone who had saved abroad all their life could get stuck at the asset limit.
What Inocencia Fiscal II changes
The votes were based on the majority report of the budget and criminal law committees, published as Orden del Día No. 209. The Senate's summary matches this text on the key points. The binding wording only comes with publication in the Boletín Oficial. So only points that appear in both sources, or that are unambiguous in the committee text, can be relied on.
The asset and revenue limits disappear
The new Article 38 of Law 27,799 opens the simplified return to individuals and undivided estates resident within the meaning of Article 116 et seq. of the Income Tax Law. The limits of 1,000 and 10,000 million pesos no longer appear in the new text. The Senate describes this as widening the circle of eligible taxpayers. Large taxpayers and certain public officials may use the simplified return, but get neither the discharging effect nor the presumption of accuracy.
The new line for newcomers
Now the sentence to watch as a new resident. Anyone who opts into the simplified return or stays in it must have been tax resident for the entire tax year for which they file it. If ARCA finds that this is not the case, you are out of the regime, and the authority may audit, estimate and impose penalties as with anyone else.
For the year you arrive, the consequence is: if you become resident during a year, that was not a full year as a resident, and according to the text the simplified return with its protective effects is not available to you for that year. Under Article 11 of the bill, the 2025 tax year is the only one exempt from this requirement. So plan for your first full calendar year as a resident to be the year from which you count on the regime, and file the year of arrival the conventional way.
The significant discrepancy is defined more narrowly
The threshold stays at 15%: a significant discrepancy exists if ARCA's objection increases your assessed tax by at least 15%. What is new is a de minimis limit: if the difference is not above 5% of the criminal threshold, it does not count. At today's threshold of 100 million pesos, that is 5 million pesos. The other triggers remain a difference above the criminal threshold itself and the use of fake invoices.
There are also rules that bind the auditors. The burden of proof for a significant discrepancy lies solely with ARCA, and the authority may rely only on your own figures and on data from its systems or from third parties. Two of the classic estimation presumptions in the procedural law (Article 18 f and g of Law 11,683) are excluded until the end of 2027, and the others may only serve as an indication that must be backed by real data. If you correct your return within 15 working days of an objection and pay, that correction does not count as a discrepancy. If an objection is later overturned, the presumption of accuracy revives retroactively, and ARCA refunds any amounts paid with interest.
The money is meant to go into the banking system
Politically, this is the heart of the law. Senator Bruno Olivera Lucero told the chamber that the aim is for hidden savings to stop being "plata muerta", dead money. To that end, the new Article 40 bis requires users of the simplified return to carry out their transactions through channels authorised by the central bank or the securities regulator. It is enough for the money to be in the financial system at the start or the end of the transaction. Cash payments at the notarial execution of a property purchase count as compliant.
Until 31 December 2027, the presumption of accuracy extends to funds used in this way. For wealth tax (Bienes Personales) they count as acquired on the day the transaction takes place. Banks and other parties subject to anti-money-laundering rules are to treat participation in the simplified return as a favourable factor, and the financial intelligence unit UIF must issue rules on this within 15 working days of publication. The due diligence duties for money-laundering prevention, however, expressly remain. So if you buy a flat with money from abroad, do not expect the bank to ask fewer questions.
Penalties fall
For micro, small and medium-sized businesses, individuals, estates and non-profit organisations that are not large taxpayers, certain fines for formal breaches fall automatically by 25%. A special regime also halves fines for formal breaches committed before the law took effect, provided the missed obligation is fulfilled. ARCA has 30 days after publication to issue the implementing rules.
What the law does not change
However much relief the package brings, three things stay as they are, and they decide whether Argentina works for you in tax terms.
Worldwide taxation stays. Neither the committee text nor the Senate's summary touches Article 1 or 116 of the Income Tax Law. If you are resident, you keep paying tax in Argentina on rent from property back home, dividends from foreign shares and interest from accounts abroad. The simplified return changes how you are audited, not what is taxable.
Tax rates stay. Inocencia Fiscal II is a procedural and penalties law. How high income tax, wealth tax and the other levies are is set out on our Argentina country page.
Residence rules stay. When you become resident is still governed by Article 116. The new requirement of a full tax year tightens what you can make of that status rather than moving it.
If you want to see the bigger picture the law sits in, you will find it in our piece on Milei's Argentina. The pattern is the same: the state is betting that trust brings more money into the system than control does.
And what does your home country say?
The protective effects of the simplified return apply only towards the Argentine tax authority. Whether your previous home country still has a say depends on whether you keep a residence there and on its tax treaty with Argentina, if there is one. Which treaty applies, and from when, depends on where you come from:
A treaty allocates taxing rights; it does not make income tax-free. The simplified return in Buenos Aires does not change that.
What you should do now
Law 27,826 has applied since 9 October 2026. That is the number to look for in Infoleg and to give your contador. The deadlines for ARCA (30 days) and UIF (15 working days) have been running since that day.
Work out your first full year. If you move in 2026 or 2027, mark the first calendar year in which you are tax resident from 1 January. From that year the simplified return becomes an option for you; according to the text, not before.
Keep your money trail clean. The protective effects depend on payments running through the regulated financial system. If you bring savings from abroad, document every transfer and use cash only where the law expressly allows it, for example at a notarial property purchase. How new residents hold their wealth in real assets in Argentina is described in our piece on Argentina as an inflation hedge.
Settle your departure at home separately. Whether you are still taxable in your home country is decided there, not in Buenos Aires. An overview of life on the ground, with the pros and cons, is in our guide to moving to Argentina, and the key facts on residence and the passport are on the Argentina country page.
The law does not turn Argentina into a low-tax country. It makes dealing with the tax authority more predictable for residents who know the rules: a full year of residence, money in the system, returns on time. Meet those three conditions and from the year after your arrival you get considerably more legal certainty than Argentina has offered so far.
Carpe Diem. Life is short and fleeting. One shot. Make it count.

