Note: subject to updates as the process moves forward

Date: October 16, 2026

The President of the Republic issued a partial objection to the bill of the Organic Law Amending the Tax Code, specifically with respect to the penalties for failure to report foreign assets in the asset declaration, which will be addressed today, October 16, 2026, by the National Assembly.

Consequently, this objection is not yet in force. We will be sending updates.

The President’s objection eliminates the National Assembly’s proposal to penalize the failure to file the Asset Declaration with 1,000 to 2,075 unified basic salaries, while maintaining the penalty equivalent to 0.5% of the unreported foreign assets, up to a maximum of 2,075 unified basic salaries.

The objection proposes the following text for the unnumbered article following Art. 105 of the Internal Tax Regime Law (“LRTI”):

“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 shall be identified by the Tax Administration in the exercise of its powers. The fine thus established may not exceed the value of two thousand seventy-five unified basic salaries.

If the declaration is filed late, and before the infraction is notified by the Tax Administration, the penalty provided for in the preceding paragraph shall be reduced by half and may not exceed the stated limit.”

The provision of the unnumbered article following Art. 105 of the LRTI, in force prior to the Assembly’s amendment bill and this partial objection by the President, states:

“Art. (…).- Penalty for concealment of assets.- Taxpayers who fail to declare to the Internal Revenue Service, in accordance with the conditions set forth in the regulations in force, the information on their assets abroad and/or their value, concealing it in whole or in part, directly or indirectly, shall be penalized with a fine equivalent to two percent (2%) of the total value of their undeclared assets and/or income, for each month of delay in filing it, which may not exceed ten percent (10%) of the value of the assets and/or income, as applicable.”

The National Assembly has a period of thirty days from the submission of the partial objection to accept it, in whole or in part, and, consequently, amend or ratify the bill of the Law Amending the Tax Code. Once the vote in this debate has concluded, the legislative body shall send the law to the Official Registry for publication.

This is a summary of the partial objection submitted by the President of the Republic to the bill of 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.

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