Argentina’s Law 27.826 took effect on Friday, 9 October 2026, after appearing in the Official Gazette. Known as Inocencia Fiscal II, it offers eligible filers of a simplified income-tax return a presumption of innocence, shields them from most challenges by the tax agency and trims some fines. Whether it shifts the balance between ordinary taxpayers and people who’ve kept savings out of sight remains an open question.
President Javier Milei promulgated the law through Decree 1160/2026, dated Thursday 8 October and signed by Milei, Cabinet Chief Diego Santilli and Economy Minister Luis Caputo. Congress passed the law on 17 September 2026. It amends Law 27.799, the first Inocencia Fiscal law, as well as the Tax Procedures Law.
What the Law Does
Resident individuals and estates can file the simplified return. Their figures are presumed accurate unless the tax agency, ARCA (Agencia de Recaudación y Control Aduanero), finds a significant discrepancy. The law defines one as at least 15% more tax, a gap above the tax-crime threshold, or fake invoices. ARCA alone must prove its case, drawing on the taxpayer’s return, its own systems and third-party data. If a ruling annuls an ARCA challenge, the agency must refund any payment with interest within 45 working days.
The target is familiar. For decades, Argentines have kept U.S. dollars at home or abroad amid inflation and devaluation, sometimes describing cash at home as dollars under the mattress. INDEC, the national statistics office, put residents’ foreign-currency cash and deposits abroad at US$268.8 billion on 30 June 2026. That figure doesn’t separate cash at home from overseas accounts. Anyone using the regime must move funds through channels authorized by the Central Bank or the National Securities Commission (CNV), the market regulator. Cash paid when signing a property deed at a notary also qualifies. Funds moved this way keep the regime’s protection until 31 December 2027.
Who Gets Relief, and Who Doesn’t
The benefits aren’t evenly spread. Formal tax fines, including penalties for missing a filing deadline, automatically fall 25% for individuals, estates, nonprofit groups and micro, small and medium-sized firms. ARCA-classified large taxpayers are excluded. A separate regime cuts fines by half for formal breaches before 9 October that aren’t final or remain unpaid, on obligations due since the first law. Taxpayers must first meet, or meet at the same time, the original obligation; earlier payments aren’t refunded.
Large taxpayers may use the simplified return only to file and pay on time, without its protections. The same limit applies to senior officials who held office during the five years before joining: secretaries of state and higher ranks, national and provincial legislators, judges, prosecutors and judicial council members. Users must be Argentine tax residents for the full year, except for the 2025 return. Tourists and foreign investors who don’t live in Argentina aren’t affected.
Rural Employers and Worker Registration
The law also rewrites penalties for rural employers who fail to register workers with RENATRE, the national register of rural workers and employers. The heaviest fine runs from 1,500,000 pesos (about US$990) to 7,500,000 pesos (about US$4,950) per worker, at an exchange rate of about 1,516 pesos to the dollar on 10 October 2026. Starting 1 January 2027, those fines will rise each year in line with the UVA, an inflation-linked unit of account.
Safeguards and Open Questions
Banks and other businesses subject to anti-money-laundering rules must treat proof of joining the regime as a favorable sign, but they still must check clients. ARCA must let them verify a client’s status through an automated query. The financial intelligence unit, UIF, has 15 working days to tell banks how to treat covered clients, and ARCA has 30 days to issue rules for halving older fines.
The law sets no target for how much hidden money should reach banks. Later central bank deposit data should show its effect. Infobae reported on 9 October that local bank shares have fallen more than 50% in dollar terms since their January 2025 peak on Wall Street. Claudio Maulhardt of Latin Securities, writing about results at Galicia, a leading Argentine bank, said he struggled to be very optimistic about banks. If Argentina does well, he added in comments cited by Infobae, its banks will do well in the future.
Why This Matters: Argentina is betting that a presumption of good faith will coax a vast pool of undeclared savings into the open. The stakes are large: INDEC counts US$268.8 billion in residents’ foreign-currency cash and overseas deposits. But the design raises fairness questions. Large taxpayers and former senior officials get no protection, while the law sets no target and leaves the payoff to later deposit data. ARCA carries the burden of proof, and banks shoulder anti-money-laundering checks, making the UIF’s 15-day guidance and ARCA’s 30-day rules the first real tests of accountability. Rural workers’ registration penalties, now indexed to inflation, will show whether enforcement keeps pace with the incentives offered to savers.