Argentina regulates ‘Inocencia Fiscal’ to bring ‘mattress dollars’ into the banking system
If a taxpayer enrolls, files, and pays on time, ARCA would be barred from reopening administrative or criminal reviews for that year and earlier periods
Argentina’s government has issued the implementing rules for its Inocencia Fiscal law, formally activating a voluntary Simplified Income Tax Regime (RSG) aimed at encouraging taxpayers to bring undeclared savings —popularly known as “mattress dollars”— into the formal economy, while shifting enforcement toward compliance “going forward.”
As detailed by La Nación, the RSG targets individual taxpayers below set thresholds —up to ARS 1 billion in income and ARS 10 billion in wealth, assessed year by year over the last three fiscal years— excluding those classified as large taxpayers. Under the scheme, ARCA will provide a pre-filled tax return and focus audits on reported income and allowable deductions, while generally avoiding checks on personal consumption and wealth variation, except under narrowly defined red-flag scenarios.
A central selling point is a tax “safe-harbor” effect: if a taxpayer enrolls, files, and pays on time, ARCA would be barred from reopening administrative or criminal reviews for that year and earlier periods, subject to exceptions such as “significant discrepancies” or fraudulent invoicing. Government officials told La Nación the simplified regime means ARCA “won’t ask for explanations” about a taxpayer’s wealth or personal spending.
Operationally, the rules specify that funds must enter the financial system either at the origin or at the destination of a transaction —for instance, depositing cash into one’s own account before paying, or transferring directly to a seller. The regulation also raises certain reporting thresholds: transactions up to ARS 10 million per month would not trigger automatic bank reporting to ARCA, according to La Nación’s account of the decree.
The regulation also updates penalties for formal non-compliance —with sharply higher nominal fines— while moving away from fully automatic enforcement by adding reminder steps and grace periods before sanctions. It additionally lifts criminal tax-evasion thresholds, including ARS 100 million for basic evasion, among other changes.
