Argentina's RIGI Regime: Complete Guide for Foreign Investors (2025–2026)

What is RIGI?

RIGI — Régimen de Incentivo a las Grandes Inversiones (Large Investment Incentive Regime) — is a comprehensive incentive framework established by Argentina's Law 27,742 (Ley de Bases), signed into law in July 2024 under President Javier Milei. It represents the cornerstone of the most sweeping economic reform package Argentina has seen in seven decades.

At its core, RIGI provides investors with a 30-year guarantee of regulatory stability on tax, customs, and foreign exchange rules, combined with a package of immediate fiscal and financial benefits. The regime targets large-scale, long-term investments in strategic sectors — and it has already attracted USD 7.82 billion across six major projects in its first months of operation.

Why RIGI Was Created

By the end of 2023, Argentina faced one of its most severe economic crises in decades: annual inflation exceeding 200%, half the population in poverty, and the Central Bank holding record-negative reserves. A complex regulatory environment had driven away foreign investment for years, creating a cycle of capital scarcity and economic stagnation.

President Milei's administration designed RIGI to break this cycle. Rather than simply offering tax breaks, RIGI primarily normalizes Argentina's regulatory framework — bringing it in line with global standards that competing investment destinations already offer. The emphasis on maintaining this normalcy for at least 30 years signals a fundamental commitment to investor certainty that Argentina had not previously provided.

The results are already visible. Within months of RIGI's launch, major projects were announced across the energy, mining and infrastructure sectors, including the largest private infrastructure investment in Argentina in the past 20 years.

Who Qualifies for RIGI

Eligible Sectors

RIGI covers investments in seven strategic sectors:

• Infrastructure — transport networks (road, rail, maritime, air), logistics, telecommunications, healthcare and education facilities
• Forestry — cultivation, management and industrial processing of timber
• Tourism — accommodation and lodging services
• Mining — exploration, development and exploitation of mineral resources, including lithium and copper
• Energy — generation, storage, transport and distribution of electricity from renewable and non-renewable sources; bioenergy; carbon capture
• Oil and Gas — LNG production, pipelines, storage, offshore exploration, petrochemicals
• Technology — biotechnology, nanotechnology, AI, aerospace, nuclear, software, robotics, defense

Investment Requirements

To qualify under RIGI, a project must satisfy two conditions: the investment must be large and long-term.

For the long-term requirement, a project qualifies when its net cash flow during the first three years does not exceed 30% of the planned capital investment's net present value — ensuring the regime applies to projects with genuine medium-to-long-term investment horizons, not short-term profit extraction.

Legal Structure — Single-Project Vehicles (SPVs)

RIGI participants must operate through Single-Project Vehicles (SPVs) — entities with the sole and exclusive purpose of developing the RIGI-eligible project. SPVs may take the form of:

• Domestic stock corporations (sociedades anónimas)
• Limited liability companies (SRL)
• Registered branches of foreign entities
• Joint ventures of any nature

Multipurpose entities may establish a dedicated branch to segregate RIGI-eligible assets and activities from their other operations.

Tax Incentives

Corporate Income Tax

SPVs benefit from a flat 25% corporate income tax rate, representing the lower bound of Argentina's standard progressive scale (25–35%). This uniform rate streamlines tax planning and enhances global competitiveness.

Dividend distributions are taxed at 7% for the first seven years and 3.5% thereafter, resulting in an effective combined rate of 30.25% initially and 27.625% after seven years — among the most competitive in Latin America for large projects.

Tax Losses — Unlimited Carryforward

RIGI eliminates Argentina's standard five-year limitation on tax loss carryforwards. SPVs may carry forward losses indefinitely. After five years, these losses can be transferred to third parties and are indexed to inflation using the wholesale price index — a critical feature for capital-intensive projects with long break-even horizons.

Accelerated Depreciation

SPVs may opt for accelerated depreciation of tangible movable assets over two annual equal installments, compared to the standard useful-life method. For assets such as mines, quarries, forests and infrastructure, depreciation may be calculated over a period equivalent to 60% of the asset's estimated useful life.

Inflation Adjustments

RIGI reinstates inflation adjustments for tax purposes using the consumer price index — a crucial safeguard in an economy with Argentina's inflation history, ensuring that financial statements reflect economic reality rather than nominal distortions.

Withholding Tax Benefits

For Long-Term Strategic Export (LTSE) projects, payments to foreign beneficiaries for maritime chartering, outbound international cargo, and EPC management services are exempt from withholding tax. All other payments to foreign beneficiaries benefit from a deemed net Argentine-source income of 30%, resulting in an effective withholding rate of 10.5%. Non-grossing-up rules apply, further reducing the effective cost of cross-border payments.

Thin Capitalization Relief

The standard limitation restricting interest deductions on related-party debt to 30% of net income is suspended for the first five years following RIGI accession — a material advantage during the investment and construction phase when debt-to-equity ratios are typically highest.

VAT Optimization

SPVs may issue VAT input credit certificates directly and automatically to their suppliers, without requiring authorization from tax authorities. Suppliers may use these certificates to pay their own VAT liabilities or request refunds if not used within three months. In practice, this provides an effective VAT exemption on purchases made by SPVs, optimizing cash flow during the investment phase.

Bank Debit and Credit Tax

The tax on bank debits and credits — widely considered one of Argentina's most distortive taxes — is 100% creditable against SPVs' income tax liabilities, neutralizing its economic effect entirely.

Customs Incentives

RIGI provides a comprehensive package of customs benefits that significantly reduces the cost of importing equipment and eliminates the risk of export restrictions:

• Import duty exemptions — new capital goods, spare parts, and components are exempt from import duties, statistical fees, and prepayment/withholding regimes from the date of RIGI registration
• Export duty waivers — goods produced under RIGI-approved projects are exempt from export duties after three years from adhesion (two years for LTSE projects)
• Unrestricted trade — no restrictions on importing or exporting goods and services required for project construction, operation, and development
• Protection from official price controls — SPVs are exempt from domestic market supply priorities and official price controls that may apply to other producers

Additionally, RIGI extends customs benefits to SPV suppliers, contingent on the fulfillment of specific conditions — creating a supply chain ecosystem around RIGI projects.

Foreign Exchange Benefits

Foreign exchange restrictions have historically been one of the most significant deterrents to foreign investment in Argentina. RIGI directly addresses this by progressively liberalizing FX rules for SPVs:

Beyond the gradual liberalization schedule, RIGI provides critical structural protections:

• No conversion requirement for capital contributions, loans, or service payments from non-residents — foreign currency can remain abroad
• Free repatriation of investment, dividends, and loan repayments without prior authorization
• No restrictions on holding foreign financial assets
• No exchange restrictions on profit distributions to non-residents, provided funds originate from RIGI-registered foreign capital contributions or loans

SPVs may also present their financial statements in US dollars, providing enhanced transparency and eliminating currency translation distortions in financial reporting.

The 30-Year Stability Guarantee

The stability clause is arguably RIGI's most valuable feature. It guarantees that all tax, customs, and foreign exchange rules in effect on the date of RIGI registration cannot be made more onerous for 30 years. This means:

• Tax rates, exemptions, and depreciation methods are locked in at registration-date levels
• SPVs benefit from any subsequent tax reductions, but are protected from any increases
• Import/export duties and procedures remain consistent for 30 years
• FX access and repatriation rights are protected for the full stability period

For LTSE projects executed in phases, the 30-year stability period begins from each phase's projected start date, capped at 40 years from the initial phase — ensuring multi-decade megaprojects receive full protection throughout their operational life.

Arbitration Rights

If disputes with Argentine authorities cannot be resolved by mutual agreement, RIGI investors have the right to pursue international arbitration under ICC Rules, PCA Rules, or the ICSID Convention. Arbitration panels consist of specialists in international tax, customs, and FX law. Decisions are binding and enforceable. State actions that violate RIGI can trigger compensation for both consequential damages and lost profits.

SPV vs. LTSE: Key Differences

RIGI creates two tiers of investment vehicles, with LTSE projects receiving accelerated benefits in exchange for higher investment commitments and the requirement to establish Argentina as a new supplier in global markets.

RIGI and OECD Pillar 2: What Multinationals Must Know

For multinational enterprise groups subject to the OECD's Pillar 2 global minimum tax (15% effective tax rate), careful analysis of the cumulative effect of RIGI benefits is essential.

Benefits that don't affect your ETR

Many RIGI benefits fall outside the scope of the Pillar 2 Effective Tax Rate (ETR) calculation under the GLOBE model rules: customs exemptions, FX benefits, VAT input credit certificates, and the bank debit/credit tax credit. Accelerated depreciation is classified as low-risk by the OECD's GLOBE model rules for eligible assets.

The risk of cumulative ETR reduction

While individual RIGI incentives may individually comply with Pillar 2, their cumulative effect can reduce the Argentine ETR below the 15% threshold, triggering a top-up tax in the parent jurisdiction. This would effectively transfer Argentina's taxing rights to the parent country — negating the value of RIGI incentives without delivering any benefit to Argentina.

Argentina has not yet implemented a Qualified Domestic Minimum Top-up Tax (QDMTT), creating uncertainty about how benefits would be reversed in cases of ETR breach. Strategic tax planning — including modeling the combined effect of all RIGI benefits on the group's global ETR — is essential before committing to the RIGI structure.

Projects Already Under RIGI

Within its first months of operation, RIGI attracted over USD 7.82 billion across six major projects:

• Southern Energy LNG (Pan American Energy, Golar LNG, YPF, Harbour Energy) — USD 2.9 billion — LNG facility in Río Negro — the largest RIGI project and largest private infrastructure investment in Argentina in 20 years
• YPF "Vaca Muerta Sur" — USD 2.5 billion — oil infrastructure and pipeline system
• POSCO Argentina — USD 1.5 billion — lithium industrial complex in Salta
• Minas Argentinas — USD 1 billion — Gualcamayo gold mining project in San Juan
• Galan Litio — USD 700 million — lithium chloride production in Catamarca
• Luz del Campo — USD 600 million — solar energy project in Mendoza

How to Structure a RIGI Investment: Key Steps

1. Confirm eligibility — verify that your project's sector, investment amount, and long-term horizon meet RIGI requirements
2. Establish the SPV — incorporate a single-purpose entity (SA, SRL, or branch) dedicated exclusively to the RIGI project
3. Prepare the investment plan — document the investment schedule, eligible assets, and NPV analysis to satisfy the long-term cash flow requirement
4. Submit the RIGI application — file with the relevant Argentine authority before the application window closes (currently July 8, 2026, extendable to July 8, 2027)
5. Obtain RIGI registration — once approved, the 30-year stability clock begins from the registration date
6. Ongoing compliance — maintain single-purpose status, submit annual operations reports, and comply with transfer pricing requirements for related-party transactions

Frequently Asked Questions

Can an existing Argentine company use RIGI?

Multipurpose entities cannot directly access RIGI for their existing operations. However, they may establish a dedicated branch or subsidiary as an SPV, segregating RIGI-eligible assets and activities. The acquisition of existing companies can also be structured to be RIGI-eligible, provided the acquired company merges into the SPV within 180 days.

What happens after the 30-year stability period?

The stability provisions continue to apply after the 30-year term expires unless expressly modified — providing additional protection to investors in the later years of their project life.

Can RIGI benefits be combined with other Argentine investment incentives?

RIGI is designed as a comprehensive regime and generally supersedes other incentive frameworks for the specific project. However, careful analysis is required to assess whether specific provincial incentives or sector-specific regimes can be combined with RIGI benefits without creating adverse tax consequences.

How does RIGI protect against future Argentine governments reversing the benefits?

RIGI's stability clause has constitutional backing under Argentina's "progress clause," protecting federal stability from local legislative changes. Additionally, investors have access to international arbitration, and any state action that impairs RIGI protections triggers the state's international responsibility, including liability for consequential damages and lost profits.