Overview
- ARCA issued an internal instruction on Friday, June 26, 2026, directing inspectors to confirm a taxpayer’s adhesion to the Simplified Income Regime, the filing of the Simplified Tax Return, and timely payment before opening audits of periods prior to 2025.
- The guidance says audits of earlier years may proceed only if a “significant discrepancy” is first found in the 2025 base period, effectively invoking the law’s presumption of exactitude known as the tapón fiscal.
- ARCA framed the instruction as temporary while Congress considers a government draft to change the law, and the agency also extended the deadline to submit the Simplified Tax Return to July 27, 2026, creating a window for taxpayers to opt in under current rules.
- Tax specialists counter that ARCA added conditions not in Law 27.799 and improperly limited the tapón fiscal, noting that the statute does not clearly exclude audits already under way and warning the move could prompt litigation over ARCA’s authority.
- The government’s anteproyecto would alter access thresholds, relax the definition of significant discrepancies, allow certain cash payments in property deeds to qualify, and create a limited dollar exteriorization window through December 31, 2027, raising broader fiscal and political stakes for high‑value taxpayers.