RIGI and RIMI: Argentina’s investment incentives compared — tax, customs and FX
Argentina currently runs two investment incentive regimes side by side: RIGI for large projects and RIMI for SMEs. They share little beyond the name: one is a comprehensive tax + customs + FX package with 30-year stability; the other, two targeted benefits in income tax and VAT. This guide compares them dimension by dimension, citing the statute behind every point.
Who qualifies
| RIGI | RIMI | |
|---|---|---|
| Eligible entity | Single-Project Vehicle (VPU): corporation, LLC, dedicated branch or JV devoted exclusively to the project (secs. 167-170, Law 27,742) | “Business taxpayers” under sec. 53 of the Income Tax Law holding a valid SME certificate, up to medium tier 2 (sec. 179, Law 27,802); Decree 242/2026 extends it to certain ARCA-registered non-profits |
| Minimum investment | USD 200 M general; higher for some sectors; onshore oil & gas USD 600 M (Decree 105/2026) | Micro USD 150,000 · Small 600,000 · Medium T1 3.5 M · Medium T2 9 M (sec. 181). Agribusiness qualifies with no threshold for irrigation, anti-hail mesh, high energy-efficiency assets and superior-genetics breeding livestock |
| Scope | Projects in eligible sectors (mining, energy, oil & gas, steel, forestry, tourism, infrastructure, technology) | New depreciable movable assets (capital/IT goods per Decree 557/2023, except automobiles) and works less than 30 % complete (secs. 180 and 182; Decree 242/2026) |
| Window | Applications until July 8, 2027 | Investments from March 6, 2026 to May 19, 2028 |
| Compatibility | — | Incompatible with RIGI for the same investments (sec. 184(f)) |
Tax benefits
| RIGI | RIMI | |
|---|---|---|
| Income tax rate | Flat 25 % for the VPU (sec. 183), versus the general scale reaching 35 % | No change: general scale of sec. 73 (25/30/35 %) |
| Depreciation | Accelerated (sec. 183): movables in 2 annual installments; infrastructure over at least 60 % of useful life | Accelerated (sec. 182): movables in 2 installments · works at 60 % of useful life · irrigation, energy efficiency, anti-hail mesh and breeding livestock fully deductible in 1 installment (immediate expensing) |
| Tax losses | No 5-year expiry, adjusted by wholesale inflation (IPIM) and transferable to third parties (sec. 183) | General regime (since Law 27,802 losses are CPI-adjusted, but they expire after 5 years and cannot be transferred) |
| Dividends | 7 %, dropping to 3.5 % from year 8 (sec. 185). Note: for the first 7 years the 7 % equals the general regime (sec. 97, Income Tax Law) | General regime (7 %) |
| VAT on investment | CERTIVA: paid or recovered through freely transferable tax-credit certificates, with no waiting period (sec. 187; General Resolutions 5589/2024 and 5682/2025) | Early refund under sec. 24.1 of the VAT Law after 3 monthly periods (versus 6 under the general regime), capped at 50 % of the annual budget quota, ranked by the age of the credit (sec. 183; sec. 9, Decree 242/2026) |
| Bank debits/credits tax | 100 % creditable against income tax (sec. 189); the general regime allows only 33 % | General regime |
| Stability | 30 years of tax, customs and FX stability (secs. 200-205) | None |
Customs benefits
| RIGI | RIMI | |
|---|---|---|
| Imports | Exemption from import duties, statistics fee and collection regimes for capital goods, spare parts and inputs of the VPU and its registered suppliers (sec. 190; GR 5590/2024) | No benefit: imports of eligible assets pay the general regime (the statistics fee remains at 3 % until Dec. 31, 2027, Decree 1140/2024) |
| Exports | Export duty exemption from year 3 (year 2 for Strategic Export VPUs) (sec. 191) | No benefit |
| Fine print | For mining, the export-duty exemption is worth little today: Decree 563/2025 already set a general 0 % — RIGI’s real value there is the 30-year stability of that 0 % | — |
Foreign-exchange benefits
| RIGI | RIMI | |
|---|---|---|
| Export proceeds | Growing free availability: 20 % in year 1, 40 % in year 2, 100 % from year 3 — that share is exempt from mandatory FX-market settlement (sec. 198); better schedules for Long-Term Strategic Export projects | No benefit: general FX regime applies |
| FX stability | The FX regime in force at accession cannot be worsened for the VPU (secs. 198-200) | — |
RIGI’s rate advantage can be neutralized by the Global Minimum Tax (Pillar Two): if the group’s parent sits in a jurisdiction with a qualified IIR, the gap between the VPU’s 25 % and the 15 % global minimum is recaptured at parent level. Sec. 196 of Law 27,742 addresses exactly this, allowing adjustments so the tax is paid in Argentina rather than abroad. The project’s corporate structure literally determines who keeps the benefit — it is mandatory pre-work, not a detail.
Two limits already flagged by scholarship (Gebhardt & Malvitano, DTE No. 554): the accelerated VAT refund was capped at 50 % of an annual budget quota — the statutory benefit is diluted by regulation — and the accelerated depreciation election, once notified to ARCA, applies without exception to all investments under the regime. Also: benefits lapse if the asset leaves the balance sheet within 2 fiscal years, with fines of up to twice the benefit enjoyed (secs. 186-187).
How to decide in five questions
- Does the investment exceed USD 200 M and admit a dedicated vehicle? → RIGI. Is it an SME investing in its own operation? → RIMI.
- Does the project depend on importing capital goods or on exporting? Only RIGI moves the customs and FX needle.
- Is there a parent in a Pillar Two jurisdiction? RIGI’s rate benefit demands structuring work (sec. 196).
- Is it an agribusiness investment (irrigation, mesh, genetics, energy efficiency)? RIMI rewards it with no minimum threshold and immediate expensing.
- Deadlines: RIGI applications until July 8, 2027; RIMI investments until May 19, 2028. Neither waits for latecomers.
Sources
- Law 27,742, Title VII, secs. 164-228 — InfoLeg · regulated by Decree 749/2024 (as amended) and amended by Decree 105/2026 (extension and onshore O&G).
- Law 27,802, Title XXIII, secs. 178-187 — InfoLeg · regulated by Decree 242/2026 (O.G. Apr. 13, 2026) and Joint General Resolution 5849/2026 (O.G. May 19, 2026).
- General Resolutions (AFIP) 5589 and 5590/2024 and (ARCA) 5682/2025 — CERTIVA and RIGI procedures.
- Scholarship consulted (Errepar, subscription): Gebhardt & Malvitano, DTE No. 554 (May 2026); Toundaian, Práctica Integral Córdoba No. 231; RIGI/CERTIVA doctrine. Cross-checked on Checkpoint (La Ley): full text of Decree 242/2026 and Joint Resolution 5849/2026.
Analysis closed on September 3, 2026. Incentive regimes change — verify before deciding. Courtesy translation: the Spanish version prevails.