Medium Investment Incentive Scheme (RIMI)

The National Executive Power, through Decree 865/2025 of 09/12/2025, convened extraordinary sessions of the National Congress to analyse, among other things, the Labour Modernisation Bill, which in Title XXIII creates the Incentive Scheme for Medium-Sized Investments (RIMI), applicable throughout the territory of the Argentine Republic, with the aim of promoting medium-scale productive investments, both domestic and foreign.

The main aspects of the scheme are detailed below.

1. Creation and scope of the RIMI

The bill provides for the creation of the RIMI as a specific regime, independent of other existing promotion schemes.

The RIMI is conceived as a regime of general application throughout the national territory and is aimed at productive investments that do not fall within the scope of the Incentive Regime for Large Investments (RIGI).

2. Objectives of the regime

The bill expressly lists the objectives of the RIMI, which include:

• Encouraging medium-sized domestic and foreign investments.
• Promoting economic development and value chains.
• Strengthening the competitiveness of different economic sectors.
• Increasing exports of goods and services.
• Fostering job creation.

These objectives define the material scope of the regime and guide its implementation.

3. Subjects covered

The aim is to benefit those third-category income tax payers who qualify as SMEs up to and including the second bracket for productive investments made in the country during the first two years of the regime's validity.

4. Productive investments

These are defined as investments intended for the production, manufacture and/or importation of new movable property (except automobiles) that is amortisable for income tax purposes, as well as for the execution of works directly related to the development of productive activities within the Argentine Republic.

Investments in financial assets, portfolios and trading goods are excluded.

For certain investments related to the agricultural sector, the minimum investment amounts for access are waived.

These are considered to have been made in the fiscal year in which the asset is verified to have been put into operation and used for the production of taxable income, in accordance with the Income Tax Law.

5. Minimum amounts

Investment amounts range from USD 150,000 to USD 9,000,000 depending on the quality of the subject.

6. Expected tax benefits

The bill provides for differential tax treatment for productive investments that meet the requirements established in the regime.

The tax benefits contemplated in the bill are mainly structured around income tax and value added tax.

6.1. Income Tax

The bill establishes that entities that adhere to the RIMI will be eligible for the following income tax benefits:

• Accelerated depreciation of capital goods used for productive investment, in accordance with the terms and conditions established by the regulations.
• Calculation of depreciation starting from the fiscal year in which the asset is put into operation and used to generate taxable income.

These benefits are applicable exclusively to assets that are part of the investment project approved under the regime.

6.2. Value Added Tax (VAT)

With regard to VAT, the bill provides for specific treatment of the tax credit linked to productive investment, which includes:

• Advance refund of VAT associated with the acquisition of capital goods and investments covered by the regime.
• The procedure, deadlines and conditions for the refund of the tax credit will be determined by the regulations issued by the Enforcement Authority and the tax collection agency.

7. Conditions for maintaining benefits

The enjoyment of tax benefits is subject to certain conditions, including:

• The goods that gave rise to the benefits must form part of the beneficiary's assets for a minimum period of two (2) fiscal years from the date on which they were used for productive activity.
• If the assets are removed or disposed of before that period, the benefits will expire, unless one of the exceptions provided for in the bill applies (replacement of the asset, destruction due to unforeseeable circumstances or force majeure, or the expiry of one-third of its useful life).

However, exceptions are provided for, including:

• Replacement of the asset with another of equal or greater value.
• Destruction due to unforeseeable circumstances or force majeure.
• Elapse of at least one third of the useful life of the asset.

The Enforcement Authority may extend the grounds for exception by means of regulations.

8. Effects of expiry

Once the expiry of the benefits has been determined by means of a well-founded administrative act, the beneficiary must:

• Refund the tax credits returned by the Treasury.
• Pay the omitted taxes, plus compensatory interest.
• Pay a fine of up to twice the amount of the exemption used.

However, exceptions are provided for, including:

• Replacement of the asset with another of equal or greater value.
• Destruction due to unforeseeable circumstances or force majeure.
• Elapse of at least one-third of the useful life of the goods.

The Enforcement Authority may expand the grounds for exceptions through regulations.

9. Conclusion

Although the bill must be considered by the National Congress and may undergo changes, the RIMI would position itself as a highly relevant incentive regime for taxpayers who were excluded from the RIGI.

Informative note prepared by Andrés Chacra, partner at ECIJA Argentina.