On October 19, 2026, the Organic Law Amending the Tax Code entered into force, after the Assembly accepted the partial objection of the President of the Republic with regard to the penalties for failure to report foreign assets in the asset declaration.

Consequently, the unnumbered article following Art. 105 of the Internal Tax Regime Law (Ley de Régimen Tributario Interno, “LRTI”) is amended to read as follows:

“Art. (…). – Penalty for failure to report foreign assets in the asset declaration.- Obligated taxpayers who must report their assets located abroad and fail to file their asset declaration; as well as taxpayers who, when filing the asset declaration they are required to file, fail to include the information on their assets located abroad, in whole or in part, shall be penalized with a fine equivalent to zero point five percent (0.5%) of the total value of the unreported foreign assets, which assets shall be identified by the Tax Administration in the exercise of its powers. The fine so established may not exceed the value of two thousand seventy-five unified basic salaries.

If the declaration is filed late, and prior to the infraction being notified by the Tax Administration, the penalty set forth in the preceding paragraph shall be reduced by half and may not exceed the stated limit.”

The previous rule penalized the concealment of assets held abroad with a fine equivalent to 2% of the total value of the undeclared assets and/or income, for each month of delay in filing the declaration, with a cap of 10% of the value of the assets and/or income.

This is a summary of the Assembly’s acceptance of the partial objection sent by the President of the Republic to the bill for the Organic Law Amending the Tax Code. It contains information that we have deemed relevant and does not necessarily reflect the opinion of Robalino®; therefore, it may not be considered as advice rendered or as a legal opinion.

If you wish to learn more about the content, please do not hesitate to contact us at unidadtributaria@robalinolaw.com.