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SURVEY OF EXTERNAL ASSETS AND LIABILITIES. Presentation Outline

Starting in 2026, the External Assets and Liabilities Reporting System will be modified, incorporating a segmented filing scheme based on the declared volume.

Thus, taxpayers whose annual balance exceeds US$10 million will be required to continue filing quarterly returns, in addition to the corresponding annual return. Conversely, those who do not reach this threshold will only be required to file the annual return.

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2026 BUDGET AND FISCAL INNOCENCE. The Senate approved both bills.

The Senate passed the 2026 General Budget and the Tax Innocence bills, both initiatives promoted by the Executive Branch that had already been approved by the Chamber of Deputies.

The 2026 Budget Law received 46 votes in favor, 25 against, and one abstention in the general vote.

The Tax Innocence Law, meanwhile, received 43 votes in favor and 26 against. This legislation introduces a comprehensive reform of the Tax Criminal Code, by increasing the application thresholds, redefining the grounds for criminal liability, and incorporating new guidelines related to the waiver of criminal charges and the extinction of legal action, along with limits derived from administrative prescription. In turn, provisions of the Tax Procedure Law are amended, notably the revision of Article 56 and the incorporation of the notion of “significant discrepancy” as an objective criterion for reducing time limits, as well as the elimination of the statute of limitations suspension mechanism provided after Article 65. It also introduces adjustments to the Civil and Commercial Code regarding the statute of limitations for local taxes and social security obligations, and establishes a simplified regime for determining Income Tax applicable to individuals and undivided estates.