On May 22, 2026, Argentina’s Executive Branch submitted to the House of Representatives a bill to establish the “Incentive Framework for Large Investments in New Industries” — officially known as “Super RIGI.” The bill was signed by President Javier Milei, Chief of Cabinet Manuel Adorni, and Economy Minister Luis Caputo, and is currently before Congressional committees. This report summarizes the key provisions of the bill, contextualizes them against the existing RIGI framework, and outlines the targeted sectors and core incentives.

I.           Executive Summary

The Super RIGI is a standalone investment promotion framework designed to attract large-scale capital into industries that do not currently exist or remain at experimental stage in Argentina. It sets a minimum investment threshold of USD 1 billion per project — five times the USD 200 million floor of the original RIGI — and offers a materially more generous package of tax, customs, labor, and foreign exchange incentives, including a flat 15% corporate income tax rate (vs. 25% under the RIGI and 35% under the general regime), full exemption from export duties (retenciones), and 30 years of regulatory stability. Projects must be channeled through a Single-Project Vehicle (Vehiculo de Proyecto Unico, or VPU), which must have an exclusive corporate purpose tied to the approved investment plan.

Unlike the RIGI, which was open to existing sectors such as oil and gas, mining, forestry, and infrastructure, the Super RIGI is restricted to genuinely new economic activities — those that are not currently produced or provided in Argentina, or whose level of development is experimental or pilot at the time the law enters into force. Projects that have already applied to the original RIGI, or that are substantially similar to such projects, are expressly excluded.

The bill also introduces binding obligations on provincial and municipal governments that choose to adhere to the regime, including a cap of 0.50% on Gross Revenue Tax (Ingresos Brutos), exemption from Stamp Tax, prohibition on new local levies, and a ban on collecting royalties or administrative fees. Any provincial or local rule that undermines the incentives granted at the national level is declared null and void.

Dispute resolution may be referred to international arbitration under the ICC, the PCA, or ICSID rules, with a seat outside Argentina and no Argentine nationals as arbitrators.

II.         Background: The RIGI and its Results to Date

The original RIGI was enacted in June 2024 as part of the Ley de Bases (Law No. 27,742). It offers a suite of fiscal, customs, and foreign exchange incentives to projects exceeding USD 200 million (or USD 600 million for upstream oil and gas) structured through a VPU. The admission window, initially set at two years, was extended by one year in February 2026 and now runs through July 2027.

Pipeline and Approvals (as of May 2026):

Approved projects span the following sectors:

A further USD 67.8 billion in projects remains pending approval, including Glencore’s El Pachon copper project (USD 11.6bn), Pluspetrol’s Bajo del Choique (USD 12.2bn), and Vicuña (USD 9.7bn, copper-gold, San Juan). More than 95% of committed investment is concentrated in hydrocarbons and mining.

III.           Eligible Sectors under the Super RIGI

The bill defines eligible “new economic activities” as any industrial, technological, or service project linked to strategic technology and digital infrastructure that, at the date the law enters into force, is not produced or rendered in Argentina, or whose level of development is experimental or pilot. Amplifications, modernizations, or reconversions of existing facilities are expressly excluded.

The Executive’s explanatory message and related communications identify the following industries as target sectors:

The final list of qualifying activities will be defined by regulation. The bill gives the Enforcement Authority discretion to assess whether a proposed project constitutes a “genuinely new” activity and to reject applications where the activity already exists at commercial scale in Argentina.

IV.         Key Benefits and Comparison with the RIGI

V.        Selected Structural Features

1.         Anti-Overlap Provision

Entities that have filed or plan to file under the original RIGI are barred from the Super RIGI. Projects with more than 50% overlap in CAPEX, location, assets, or production capacity relative to an existing RIGI applicant are treated as “similar projects” and are also excluded, even after restructuring, spin-offs, or ownership changes designed to circumvent the restriction.

2.         Provincial Adherence

Super RIGI incentives are only available for projects located in provinces that formally adhere to the regime. Adhering provinces must: (i) cap Turnover Tax at 0.50%; (ii) exempt all project-related transactions from Stamp Tax; (iii) refrain from imposing new levies or royalties; and (iv) waive the solve et repete rule, meaning they may not require payment as a condition for appealing tax assessments. Adherence is irrevocable as to previously approved projects, even if the province subsequently withdraws from the Super RIGI.

3.         Approval Process

The Enforcement Authority (to be designated by the Executive) has 90 business days to approve or reject a submitted investment plan. Rejection is non-appealable, but applicants may resubmit up to two additional times within the same calendar year. Rejection grounds are exhaustively listed in Article 19 and are limited to factual and legal deficiencies; the decision may not be discretionary. Approved projects receive protection equivalent to a property right from the date of adherence (Article 24).

VI.        Legislative Status and Next Steps

As of this memorandum’s date, Bill No. 0005-PE-2026 has been formally received by the House of Representatives and referred to the Committees on Budget and Finance, Industry, and Science, Technology and Innovation. Congressional debate has not yet been scheduled. The administration intends to seek treatment before the July congressional recess. Given that the original RIGI required significant negotiations with the Senate before final passage, the Super RIGI may face analogous scrutiny, particularly regarding the scope of provincial fiscal obligations and the exclusion of local content requirements.

Once approved, the Executive will have 90 calendar days to issue implementing regulations, after which the five-year application window will open.