ARCA tightens control of the tax domicile after the Tax Innocence law and imposes fines of up to $35 million

The measure was published in the Official Gazette through General Resolution 5809 and will begin to rule on Monday, March 2, 2026. From that date, changes of address must be made exclusively digitally and within a maximum period of 10 business days administrative since the novelty occurs.

“The tax domicile becomes a critical variable”warned tax expert Sebastián Domínguez, CEO of SDC Asesores Tributarios. And he added: “With the Tax Innocence Law The amounts of fines were increased very significantly, Therefore, having the address correctly reported is no longer a minor formality.”

According to current regulations, not complying with the update in a timely manner can lead to sanctions provided for in article 39 of Law 11,683, whose amounts were raised by a range of between $150 and $45,000 to another that goes from $150,000 up to $35,000,000.

Starting in March 2026, the modification of the tax address must be carried out by entering the “Registration System” service, within the “Single Tax Registry”, option “Domiciles”, and presenting the electronic form 420/D, with a Tax Code level 3 or higher.

The system will allow you to select addresses that have already been previously verified by ARCA or other organizations. In those cases, the address will automatically be in status “Confirmed” and it will issue the corresponding certificate.

When the address is not among those previously verified, the taxpayer must upload it manually and attach supporting documentation – such as utility bills, bank statements or insurance policies. In this case, the address will remain in the “Declared via Internet” status and will be reviewed by ARCA, which will have up to seven business days to accept or reject it.

If observed, A period of 30 calendar days will be granted to correct inconsistencies. If you do not do so, the address may be classified as “Non-existent-Unknown”.

“A home with that qualification is not a minor issue.”: can enable ARCA to establish an ex officio tax domicilewith full legal effects,” explained Domínguez.

The new scheme also eliminates sending confirmation codes by postal mail, which governed under the previous regime. The entire process is centralized on digital platformswhich simplifies the process, but also transfers greater responsibility to the taxpayer.

Besides, ARCA may limit the possibility of modifying the address according to the taxpayer’s risk profile (SIPER) or the administrative status of the CUIT. In these cases, the procedure can only be carried out through “Digital Presentations”.

For Domínguez, the regulatory change leaves a gray area in terms of proportionality. “The increase in sanctions was not accompanied by a graduation scheme by size or economic capacity,” he noted. And he added: “A fine of up to $35 million may be reasonable for a large taxpayer.”but it is clearly priceless for an SME for a merely formal breach.”

In that sense, the specialist did not rule out that the new regime could lead to administrative and judicial issues. “The absence of objective parameters weakens the principle of reasonableness in the application of sanctions,” he concluded.