ARGENTINA Trends and Developments Contributed by: Daniel Rinci, Tomas Cabanelas, Fernando García and Marisa Majul, Rinci & Asociados
Although Milei’s party won the mid-term elections with over 40% of the popular vote, economic and political actors are still cautious regarding Argentina’s eco - nomic and political future, mainly due to a history of somewhat erratic changes. Ongoing Reforms Important reforms have been passed by congress during Milei’s government, including special invest - ment regime, taxation and labour reforms. The Large Investment Incentive Regime (RIGI) Argentina has long struggled to attract sustained for - eign investment, hampered by regulatory uncertainty, currency controls, and an unpredictable tax environ - ment. The Large Investment Incentive Regime – Régi- men de Incentivos para Grandes Inversiones (known by its Spanish acronym, RIGI) – represents the Milei administration’s most ambitious attempt to change that narrative. Enacted as part of the broader “Bases Law” reform package, the RIGI offers a comprehen - sive bundle of tax breaks, foreign exchange freedoms, and legal protections specifically designed for large- scale, long-term projects. Qualifying investments The RIGI targets investment projects of at least USD200 million in nine sectors: forestry, tourism, infra - structure, mining, technology, steel, energy, and oil and gas. Each sector carries its own minimum invest - ment threshold – oil and gas upstream projects, for instance, require a minimum of USD600 million, while general projects start at USD200 million. To access the regime, investors must operate through a dedi - cated special purpose vehicle (SPV) the sole purpose of which is the promoted project. The entry window is currently open until July 2027, following a one-year extension granted by the Executive in early 2026. Projects must also qualify as long-term investments, meaning that the expected cash flows generated in the first three years cannot exceed 30% of the capital planned for that same period – a built-in filter to ensure the regime is used for genuinely capital-intensive ven - tures rather than short-term plays.
The incentive package The financial benefits are substantial. On the tax side, corporate income tax is capped at 25% – well below the standard 35% rate. Investors benefit from accel - erated depreciation, unlimited loss carry-forwards (transferable to third parties after five years), and a sig - nificantly reduced withholding tax on dividends: 7% initially, dropping to 3.5% after seven years. Imports of capital goods, spare parts and consumables are fully exempt from customs duties, and export duties are lifted entirely after two to three years of operation, depending on the project type. On the foreign exchange front – historically one of the most sensitive issues for foreign investors in Argen - tina – the RIGI provides a gradual but complete path to free currency disposal. Export proceeds become progressively exempt from the obligation to be settled in the local foreign exchange market, reaching 100% freedom four years after the project commences operations (three years for strategic export projects). Capital contributions, loans and other financing flows are freely available from the outset. Stability and legal protection Perhaps the most distinctive feature of the RIGI is its 30-year stability guarantee. Once admitted to the regime, an SPV locks in the tax, customs, and foreign exchange conditions in force at the time of its applica - tion. Future legislative changes that would normally negatively affect those conditions simply do not apply. The law goes further, granting these rights constitu - tional-level protection equivalent to private property – meaning any national or provincial rule that under - mines them is automatically null and void. Disputes between investors and the State can be sub - mitted to international arbitration under the rules of the ICC, the PCA, or ICSID, without the need to exhaust domestic administrative remedies first. The seat of arbitration must be outside Argentina. Early results The regime is already generating tangible activity. As of early 2026, 12 projects have received formal approval, representing combined commitments in excess of USD26 billion. These include major energy infrastructure such as the Vaca Muerta Sur pipeline,
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