since when it has been in force, what taxes it covers and how to adhere to the payment plans

The initiative intended to benefit the taxpayers of the City of Buenos Aires will come into effect on November 3date from which regulate debts due until August 31, 2025. The plan will include forgiveness of interest and penalties and will have a payment facility scheme of up to 48 installments.

The moratorium was made official through the resolution 461 of the organism that leads German Krivocapich which establishes “the conditions for acceptance, the scope of tax benefits, the expiration terms, the configuration of the default and the parameters for the cancellation of obligations, among other aspects.”

Taxes achieved

The regulations emphasize that their application will cover “owed tax obligations of any nature” that are due on August 31, 2025 inclusive, whether they are in an administrative or judicial instance and whether they are levies that are collected, determined and supervised by the AGIP. In that sense, its scope will allow regularization of Gross Income, ABL, real estate tax and automobile licensesamong others. It will also allow the incorporation of fines with a final sentence and will enable the reformulation of current payment plans, with exceptions.

Bankruptcies and accession dates

In that framework, the AGIP determined a series of express exclusions. For example, those declared bankrupt without continuity of exploitation, those convicted of tax crimes with a final sentence or with an approved settlement agreement, and those convicted of crimes against the GCBA will not be able to access the moratorium. Expirations of plans established by the regularization regime, current plans with forgiveness benefits and collection agents for withheld amounts will be excluded, as explained by the tributary Sebastián M. Domínguez, CEO of SDC Tax Advisors.

The period of accession to the moratorium will begin on November 3, 2025 and end on January 31, 2026, both dates inclusive. As stipulated by law, the AGIP will have the power to extend the deadline for 90 calendar days.

Payment plans

The Regime of Regularization of Tax Obligations will offer a range of payment options to the taxpayer. They may be paid in cash or in up to 48 installments, with partial or total remission of interest, depending on the date of accession and type of taxpayer.

In the case of the “General taxpayers”the cash payment method will offer a forgiveness of 100% of the interest if it is paid in 30 days, 70% if it is between 31-60 days, 50% if it is chosen for 61-80 days and 40% from 81 days. In the event that they opt for a payment plan in installments, a forgiveness of 70% will be offered within 30 days, 50% between 31-60 days, 40% between 61-80 days and 30% after 81 days.

For “Large Taxpayers”the cash payment scheme will be as follows: 70% interest forgiveness in 30 days, 60% between 31-60 days, 40% between 61-80 days and 30% after 81 days. If the installment plan is chosen, the forgiveness will be 60% if the cancellation is chosen in 30 days, 40% between 31-60 days, 30% between 61-80 days and 10% from 81 days.

Financing

The financing rate in installments will be 2% per month for general taxpayers. In the case of large taxpayers it will rise to 3%. In both cases the minimum amount per installment is $5,000. So that the plan does not lose validity, the single payment must be made before the 10th of the month after joining or, failing that, the first following business day in case of disability. If it is a payment plan, the first installment will expire under the same schedule.

Debts in court

If it were debts in courtthe taxpayer must make an adhesion for each judgment including the entire debt executed. In that case, the procedural deadlines will be suspended until the total owed is paid and the precautionary measures will be lifted. To access, you must pay the court fee, expenses and fees of the representative, which can be paid in up to 6 installments.

Regarding cases that are framed within the Criminal Tax Regime, acceptance of the regularization regime suspends criminal action during the process. If the plan is completed, it will be extinguished. Otherwise, criminal actions against the taxpayer will continue.

Regarding formal sanctions, their ex officio condonation will be subject to compliance with the formal duty omitted until August 31, 2025. If the formal duty infringed is not capable of being fulfilled subsequently, the condonation will operate ex officio when the fault has been committed prior to said date. Furthermore, it establishes that all fines for which no final judgment has been issued will be condoned “ex officio”, provided that they have been cancelled, incorporated into a current or regularized payment facility plan.

Plan expiration

The expiration of the plan occurs for three reasons. On the one hand, when there is a failure to cancel 2 installments, either consecutively or alternately, within 60 calendar days after the expiration date of the second of them. The same will occur in the event of non-payment of the unpaid installment/s, 60 consecutive days from the due date of the last installment of the plan. Finally, when the payment of the fee corresponding to the reinstated early cancellation is not recorded. The expiration will imply the loss of benefits, reestablishing sanctions, compensatory and punitive interests, and criminal actions will continue.

How to adhere to the Regime for Regularization of Tax Obligations of CABA

Membership must be made through www.agip.gob.ar, which can be accessed with the miBA Level 3 password. The taxpayer must report the debts, the payment method and the bank details for automatic debit in case of payment in installments.

If you choose to pay in cash, it must be made until the 10th of the month immediately following the month of placement or the following business day if that day is a holiday, non-working day or non-administrative or banking business day. If it is paid in installments, the first installment will be due on the 10th of the month immediately following the month of placement or the following business day if that day is a holiday, non-working day or non-administrative or banking business day.

For Domínguez, the regularization regime “represents a strategic tool to normalize tax liabilities with important economic and legal benefits. The partial or total remission of interest and penalties, along with the possibility of regularizing in up to 48 installments, makes it a financially convenient alternative, especially in a context of high tax burden and increasing financial costs.”

The tax expert recommended taking into account six points when analyzing whether it is advisable to take advantage of the moratorium. In that sense, he highlighted:

• Evaluate early foster care: The sooner you join, the higher the percentage of interest forgiveness will be. This directly impacts the final cost of regularization.
• Comprehensively review the fiscal status of the company: Do not limit yourself to the debts already identified. It is advisable to carry out a comprehensive survey of the company’s tax status. It may be advisable to carry out a tax audit to detect contingencies that can be regularized in this plan.
• Analyze the criminal impact: In cases with risk of criminal tax sanctions, shelter not only avoids legal action, but also allows the criminal action to be terminated with compliance with the plan.
• Consider reformulating current plans: If current plans have higher rates or less flexibility, reformulating them under this regime can improve financial conditions. This is provided that they are not among those in which reformulation is not allowed.
• Plan the flow of funds: Although there are facilities, the expiration of the plan implies the total loss of benefits. It is important to project monthly payments and provide funds to comply without delays. For disorderly taxpayers, who do not keep track of bank balances, it may be convenient to pay in cash or in a smaller number of installments.
• Consult with your tax advisor: Each case has particularities (judicial, accounting, criminal or financial) that require a comprehensive professional analysis to make the best decision.