Special Tax Settlement Regime: Scope and Benefits

Eligible Debts

  • Tax

  • Customs

  • Social Security Contributions

The regime covers debts with due dates up to March 31, 2024. This includes obligations currently under administrative or contentious-administrative dispute, provided the taxpayer submits (allanamiento) or withdraws the claim (desistimiento), as applicable, and waives the right to a refund action (acción de repetición). It also includes obligations of withholding and collection agents who failed to withhold/collect, or failed to remit funds after the corresponding deadline.

Enrollment Period: From the effective date of the regulations up to 150 running days thereafter.

Benefits for Enrollment

Enrollment in the regime provides benefits consisting of the waiver (condonación) of interest and fines. Regarding compensatory and punitive interest, the waivers will be more extensive for debtors who regularize within the first 30 days, decreasing as the period extends or depending on the chosen payment method.

Payment Methods and Interest Waivers

Waiver of compensatory and punitive interest accrued as of the enrollment date:

Payment Method Enrollment Period Interest Waiver
Cash or 3-Installment Plan Within 30 running days of the regulation’s effective date 70%
Between 31 and 60 running days 60%
Between 61 and 90 running days 50%
Existing/Lapsed Plans For taxpayers with obligations due as of 03/31/2024 included in active or lapsed plans 30%
Installment Plan (36, 48, 60, or 84 installments) Within 90 running days 40%
After 91 running days 20%

For applied fines, the waiver will be 100% in all cases.

Installment Plan Terms

Terms are established based on the type of taxpayer:

Taxpayer Type Down Payment Max. Installments Observations
All Taxpayers None 3 Applicable to debts due by 03/31/2024, including those in active/lapsed plans.
Individuals 20% 60 Excluding those classified under RG AFIP 5321.
Micro & Small Enterprises 15% 84 Including those classified under RG AFIP 5321.
Medium-Sized Enterprises 20% 48
Other Entities 25% 36

Additional Provisions

  • Interest Rate: The financing interest will be calculated based on the commercial discount rate set by the Banco de la Nación Argentina, as established in the regulations.

  • Waiver of Fines and Sanctions: Enrollment entails a 100% waiver of non-final (no firmes) and unpaid fines for infractions committed up to March 31, 2024, provided the material or formal obligations were fulfilled or rectified by said date.

  • Legal Fees: For debts under dispute before the Tax Court or in contentious-administrative proceedings (including tax executions), legal fees will be reduced by 50% if enrollment occurs within the first 90 running days of the regulation’s effective date.