Resources · Practical Guide
RIGI in Vaca Muerta
Incentive Regime for Large Investments: an executive guide for investors and companies operating in, or looking to enter, the Neuquén Basin. Law 27,742 · Decree 749/2024 · Decree 105/2026.
01 — The regime
What the RIGI is and why it changes the rules
The Incentive Regime for Large Investments (Title VII, Law 27,742 the “Ley de Bases”) creates a special investment category — the Single Project Vehicle (VPU) — with a distinct tax and regulatory status frozen for 30 years. It was implemented by Decree 749/2024 and extended to July 2027 by Decree 105/2026, which also brought onshore oil and gas upstream into scope.
Eligible activities in Vaca Muerta
| Activity | Minimum investment |
|---|---|
| Onshore exploration and production (E&P) | USD 600 million |
| Hydrocarbons transport (oil and gas pipelines) | USD 300 million |
| Liquefied natural gas — LNG | USD 200 million |
| NGL processing (ethane, propane, butane) | USD 200 million |
| Power generation associated with extractive projects | USD 200 million |
Admission requirements
- Incorporate a Single Project Vehicle (VPU) — a legal entity dedicated exclusively to the project
- Minimum investment by category, with 40% disbursed in the first 2 years
- Evidence technical and financial capacity before the Secretariat of Mining and Investments
- Commit at least 20% of contracting to local suppliers in categories where local supply is available
- Detailed investment plan with a timeline and verifiable milestones
- No outstanding tax or social security debts in the previous 3 years
02 — The benefits
The full incentive package
The RIGI offers the broadest set of tax incentives ever approved in Argentina for private investment. The benefits are cumulative.
The historical difference
Regulatory stability for 30 years
No investment in Argentina had ever enjoyed a stability guarantee of this magnitude. The RIGI establishes that no subsequent law, decree, resolution or administrative act may alter the benefits of an approved VPU — including tax rates, export duties, import duties, the foreign exchange regime and price regulation.
In the event of any breach, the investor may go directly to international arbitration (ICSID, ICC or PCA) without exhausting local remedies — an unprecedented concession in Argentine regulatory history.
03 — Tax burden
General regime vs. RIGI: the real difference
Without the special regime, operating in Argentina means one of the heaviest tax structures in the region. The RIGI does not eliminate every tax — but it changes the ones that matter most for large-scale investment projects.
| Tax | General regime | Under the RIGI |
|---|---|---|
| Income tax | 25%–35% (progressive) | Fixed 25% |
| VAT on capital goods | 10.5% | Exempt (tax certificate) |
| Export duties on shale | 8% | 0% from year 3 |
| Dividends paid abroad | 7% | 3.5% from year 7 |
| Import duties on capital goods | Variable | 0% |
| Financial transactions tax | 0.6% per transaction | 0.6% (unchanged) |
First projects approved
| Project | Investment | Activity | Status (Mar 2026) |
|---|---|---|---|
| VMOS | USD 2,486–2,900M | 550,000 bpd pipeline | 51%+ construction progress |
| Southern Energy | USD 6,878M | LNG 2.45 Mtpa | FID taken · under construction |
| Argentina LNG | ~USD 20,000M | LNG 12 Mtpa | FID expected mid-2026 |
| TGS NGL | USD 3,000M | NGL processing | Under review |
04 — Foreign investors
Considerations for investors from abroad
Argentina has double taxation treaties with 23 countries: the United Kingdom, Spain, France, Germany, China, Brazil, Chile, Canada and Australia, among others. There is no treaty with the United States — a critical factor that makes it essential to plan the corporate structure from the outset to avoid double taxation.
With no double taxation treaty with the United States, the VPU structure must be planned carefully to avoid taxation in both jurisdictions. Raskovsky y Asociados coordinates with international tax advisors specializing in investment structures for Vaca Muerta.
The “sixth method” in transfer pricing
Argentine rules follow OECD principles but include a “sixth method” that is particularly aggressive for commodity exports — crude oil included. It takes the quoted market price on the shipment date as the reference (or the higher of shipment and invoice date), regardless of the price agreed between related parties. For large-scale export projects it can generate significant tax adjustments. Offtake and trader structures must be designed with this rule in mind from the start.
Foreign exchange regime after the capital controls
Foreign exchange controls were lifted on 14 April 2025 as part of a program with the IMF (USD 20 billion). The new regime is a managed float within bands (ARS 1,000–1,400 per USD). Companies may remit profits from the 2025 financial year onwards. The RIGI grants free availability of 100% of foreign currency from year 4 of the VPU — going beyond the general regime’s restrictions.
05 — Structuring
How to set up a VPU
The Single Project Vehicle is the centerpiece of the RIGI. Structuring it correctly from the outset determines both eligibility and the ability to make full use of the benefits.
Eligible legal forms
- Sociedad Anónima (SA, corporation) — the preferred form for upstream projects, for its limited liability, transferable shares and eligibility in capital markets
- UTE (joint venture) — eligible as a VPU; the dominant structure for joint ventures with Gas y Petróleo del Neuquén (GyP), a mandatory partner holding at least 10%
- SA with a foreign shareholder — the foreign partner must register under Sec. 123 of Law 19,550 before the VPU is incorporated
- Branch (Sec. 118) — not advisable: it entails unlimited liability of the parent company
The process step by step
- Step 1 — Incorporate the VPU as a separate legal entity whose corporate purpose is limited to the project
- Step 2 — Prepare a detailed Investment Plan with a timeline, milestones and sources of financing
- Step 3 — File with the Secretariat of Mining and Investments — the single RIGI window
- Step 4 — Technical and financial assessment (60 days, extendable by a further 30)
- Step 5 — Approval resolution and signature of the project agreement
- Step 6 — RIGI clock starts — years 1 to 30
Frequently asked questions
What we are asked most
Can a company already operating in Vaca Muerta join the RIGI?
Yes, by incorporating a VPU for a new project or expansion phase. Pre-existing assets stay outside the VPU. The project must be new and clearly definable — not a reorganization of assets already in operation.
Does the RIGI apply to service providers, not only operators?
It is designed for large-scale productive projects. That said, service companies building dedicated physical infrastructure (water treatment plants, logistics parks) with sufficient investment could qualify under associated infrastructure categories. Each case requires specific analysis.
What happens if the government amends or repeals the RIGI after approval?
The project agreement signed on approval of the VPU is an administrative contract with full legal force. The 30-year stability survives even if Congress repeals the RIGI. In the event of a breach, the investor can go directly to international arbitration without exhausting local remedies.
Does the RIGI protect against exchange rate changes?
The RIGI guarantees free availability of foreign currency (100% at year 4) and exemption from export duties from year 3. It does not fix the exchange rate — the project operates in the prevailing FX market. The protection lies in freedom of access to the market, not in the parity.
How long does approval take?
The implementing rules set 60 days for the initial assessment, extendable by a further 30. In practice, the first projects took between 3 and 6 months. Well-documented projects with no additional conditions tend to be approved faster.
Is there a deadline to apply for the RIGI?
Yes. Decree 105/2026 extended the deadline to July 2027. VPUs approved before then keep all their benefits for 30 years. Given the complexity of structuring, we recommend starting the process no less than 12 to 18 months in advance.
Raskovsky y Asociados · Vaca Muerta Desk
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Raskovsky y Asociados · Buenos Aires
Corporate, contractual, employment and hydrocarbons regulatory practice. More than four decades advising in complex regulatory environments.
GZ Estudio Contable · Buenos Aires
Tax, corporate, audit and tax planning services, with an active client base in the hydrocarbons industry.
Own office · Av. Manuel Belgrano, Lote 1 Manzana 362, Q8305, Añelo, Neuquén.
On-site follow-up and direct contact with operators and provincial authorities.
What we are asked most
Do you need advice on the RIGI?
Our team specializing in hydrocarbons law, international tax and investment structuring can support you from the initial assessment through to VPU approval and beyond.
Professional information document; it does not constitute legal, tax or accounting advice. © Raskovsky y Asociados — Vaca Muerta Desk.
