Argentina is undergoing an unprecedented structural transformation under the government of Javier Milei. In this context of sweeping economic reforms, the country is preparing to launch a tax amnesty program that will allow individuals and companies to regularize undeclared assets, particularly those held abroad.

This measure gains significance at a time when the Automatic Exchange of Financial Information (CRS) is being consolidated with over 90 countries around the world, including OECD and G20 members, as well as other jurisdictions adhering to the Common Reporting Standard (CRS).

According to recent estimates by the Ministry of Economy and the Federal Administration of Public Revenues (AFIP), Argentinians hold over USD 370 billion outside the tax system, much of it deposited in offshore bank accounts or invested in undeclared assets. In this context, the government aims to encourage the repatriation of capital and broaden the tax base through a regime that combines tax incentives with the threat of imminent audits.

Global Transparency and CRS: What You Need to Know

Since 2017, Argentina has participated in the Common Reporting Standard (CRS), the OECD’s international framework that enables the annual exchange of financial information between countries. This includes data on bank accounts, investments, trusts, and offshore structures held by Argentine residents abroad.

According to the OECD’s 2025 Latin America Fiscal Transparency Report, Argentina has collected over €491 million thanks to the CRS. In addition, it maintains active cooperation with the G20, which expands the global tax enforcement network.

Milei and His Fiscal Revolution

Since taking office in December 2023, the Argentine president has implemented an aggressive economic reform plan:

• Elimination of ministries and cuts in public spending.

• Removal of more than 300 tax and labor regulations.

• Opening of the foreign exchange market with free circulation of the U.S. dollar.

• First primary fiscal surplus in over a decade.

Among the most striking measures is the elimination of tax controls on the entry of cash dollars. As of July 2025, individuals are allowed to deposit up to USD 85,000 in financial institutions without having to justify the origin of the funds, as part of the “Argentine Savings Historical Reparation Plan.”

According to El País, Milei aims to attract part of the more than USD 270 billion that Argentines keep outside the formal banking system or abroad, driven by decades of inflation, devaluation, and distrust in the state.

What does the new tax amnesty consist of?

The new program, officially called the “2025 Asset Regularization Regime,” includes the following aspects:

Reduced rates based on the destination of the capital

• Voluntary regularization of undeclared assets and funds, both domestic and abroad.

• Reduction of penalties and compensatory interest in cases of full or partial payment of omitted taxes.

• 8% special tax if the funds remain abroad.

• 3% to 5% if the funds are repatriated and invested in Argentina, in strategic sectors such as real estate, public or private bonds, or capitalization of national companies.

• 0% in specific cases if the funds are deposited in Argentine banks before December 2025.

Complementary Measure: Adjustment of Tax Losses

In parallel, the government has implemented a special regime, valid until July 31, 2025, allowing taxpayers to correct errors in the calculation of carried-forward tax losses without penalties. This measure is aimed at companies with inconsistencies in their tax filings that wish to regularize their situation without undergoing extensive audits.

Risks and Challenges

While the proposal offers clear advantages, it has also sparked criticism:

• Experts warn that the lack of controls could open the door to money laundering.

• NGOs and opposition leaders fear a repetition of the pattern of “perpetual tax amnesties” with no consequences for repeat offenders.

• The social impact of the economic adjustment (with poverty rates exceeding 50%) could jeopardize the political viability of the plan if it is perceived as a benefit reserved for the wealthy.

Nevertheless, many analysts agree that this may be the last realistic opportunity to regularize offshore assets with tax benefits and no criminal prosecution, before international mechanisms like the CRS permanently close in.

Why now?

Argentina has adhered to the OECD’s Common Reporting Standard (CRS) since 2014, although its implementation in previous years was partial. However, in 2024, the tax authority (AFIP) has forcefully resumed the enforcement of automatic exchange agreements, beginning to receive and cross-check financial information from over 100 jurisdictions, including Switzerland, Uruguay, the United States (in a limited scope through FATCA), and several European countries.

This means that Argentine taxpayers with undeclared assets now face a high risk of detection and potential legal, financial, and even criminal consequences.

Moreover, recent experiences in countries like Chile, Colombia, and Brazil—which implemented tax amnesty regimes in recent years—have shown that such programs can generate immediate fiscal revenue, expand the tax base, and strengthen the taxpayer-government relationship when implemented with clear rules and sustainable fiscal policy goals.

Recommendations for Taxpayers and Investors

If you or your company hold undeclared assets abroad, this may be the last window of opportunity before data sharing with AFIP becomes irreversible. The key steps are:

• Conducting a comprehensive tax diagnosis of undeclared assets.

• Assessing the legal and tax implications of regularization.

• Planning for efficient repatriation or reinvestment with the support of legal and accounting advisors specialized in international taxation.

• Analyzing whether existing international structures can be adapted to a transparent, legal, and fiscally sustainable framework.

In this context, the Argentine Tax Amnesty aligns with a global trend of increased control over offshore capital and growing tax scrutiny. Far from being merely a revenue-generating measure, it represents a strategic opportunity to regularize, protect, and invest assets securely.

Today, it’s not just about declaring—it's about planning wisely, leveraging available benefits, and safeguarding wealth in a world of full financial transparency.

Need Support to Regularize Your Tax Situation?

If you're considering taking advantage of the Tax Amnesty in Argentina, we invite you to contact Richards, Cardinal, Tützer, Zabala & Zaefferer S.C. Our experts in international taxation, asset structuring, and compliance strategies across multiple jurisdictions are ready to assist you.