Milei’s RIGI: $200M Minimum, 30-Year Tax Lock, Not for Most Bitcoiners

Régimen de Incentivos para Grandes Inversiones (RIGI) is Argentina’s $200 million investment-incentive instrument under Law 27,742, signed in July 2024. Its 30-year tax-stability guarantee has been treated in some English-language coverage as a path to Argentine residency or citizenship. It is neither. It is an industrial-policy regime built for large industrial and energy projects, and the residency conversation runs on a different statute.

RIGI is the Régimen de Incentivo para Grandes Inversiones, enacted as Title VII of Law 27,742 (Ley Bases) on July 8, 2024, and regulated under Decree 749/2024. It is a thirty-year tax-and-regulatory-stability lock for industrial-scale investments above a US$200 million threshold, structured as a corporate-vehicle benefit, not a personal residency pathway. For the right Bitcoin-treasury company, it is among the most generous investment-incentive regimes on the planet. For the typical individual Bitcoiner researching Argentina as a sovereignty move, it is the wrong file entirely.

This is the breakdown: what RIGI offers, who qualifies, and why most Bitcoiners reading about it should set it aside and pursue a different path to Argentine residency or citizenship.

What RIGI Actually Is

RIGI is a tax-and-regulatory stability regime for capital-intensive projects in eight strategic sectors. It is administered by the Ministry of Economy and applies to a "Sole Project Vehicle" (Vehículo de Proyecto Único, or VPU), a corporate entity established specifically to execute the qualifying investment.

Three points to internalize before going further.

01 / The benefits accrue to the corporate vehicle, not the natural-person investor. RIGI does not grant residency. It does not grant citizenship. It does not put the investor on a path to either. The benefits attach to the project’s corporate entity for thirty years.

02 / The bar to entry is structural. US$200 million per project minimum, with sector-specific tiers running up to US$300 million for oil and gas transportation and storage. A small subset of strategic projects carries a US$100 million floor. These are infrastructure-scale numbers, not individual-investor numbers.

03 / The application window has a clock. The original adhesion window ran two years from the law’s entry into force on July 8, 2024, expiring July 8, 2026. Decreto 105/2026, published in the Boletín Oficial on February 19, 2026, exercised the one-time extension allowed under Article 168 of Law 27,742 and pushed the window one year, to July 8, 2027. The regime itself runs thirty years from project approval.

The $200m Threshold

The minimum investment is the rule that filters most Bitcoiner inquiries out. Two-hundred million US dollars in qualifying capital, deployed against a single project, in one of eight eligible sectors, structured through a Sole Project Vehicle.

The $200M is not a one-time requirement that empties on day one. The regime requires that at least 40% of the qualifying investment be deployed within the first two years of project approval. For a project that does not hit the 40% milestone in time, the benefits fall away and the project loses access to the regime.

The threshold is also project-scoped. Two separate $100M projects do not aggregate into a qualifying $200M file. Each VPU is evaluated standalone.

For a Bitcoin-treasury operation deploying at industrial scale (a mining facility complex, a generation-and-mining stack, a dedicated grid-scale colocation buildout), $200M is reachable. For an individual Bitcoiner with seven or eight figures of personal stack, it is not. The regime was not designed for individual investors. It was designed to compete with foreign-investment incentive packages in Brazil, Chile, and Mexico for capital-intensive projects in the resource and infrastructure sectors.

The 30-year Stability Lock

The headline benefit is a thirty-year freeze on the tax and regulatory framework that applies to the project. Argentina has, historically, made promises to investors and then changed the rules. RIGI is the legal answer to that pattern: a contractual-grade commitment that the project’s tax exposure, customs treatment, currency-conversion access, and core regulatory framework cannot be increased or made less favorable for the duration.

The mechanism is statutory. Title VII of Law 27,742 creates a contractual relationship between the Argentine state and the qualifying VPU, enforceable under the regime’s stability clause. A project that qualifies on day one operates under the same tax stack on day 10,950.

Stability covers four axes:

01 / Tax stability. Federal taxes applicable to the project cannot be increased above the rate at the time of approval. New federal taxes targeted at the project sector cannot be applied. Provincial and municipal taxes, where the relevant province has signed onto the regime, are similarly frozen.

02 / Regulatory stability. Sector-specific regulations applicable to the project cannot be tightened in ways that materially increase compliance cost or operational restriction.

03 / Customs stability. Import-duty treatment for capital goods, intermediate inputs, and project-related imports is locked at the entry-rate framework.

04 / Currency stability. RIGI projects have guaranteed access to the official foreign-exchange market for paying dividends abroad after a graduated schedule (year-by-year increasing remittance allowance), bypassing the parallel-market workaround that has historically made dollar dividends from Argentina functionally illiquid.

Four-axis stability, locked for thirty years, in a country where the macro variable that hurts foreign investors most often is rule changes. That is what RIGI is selling.

The Tax Benefits Package

Within the stability framework, the actual tax treatment is also more favorable than the ordinary regime.

Corporate income tax drops from 35% to 25%, a ten-point reduction that is itself locked for thirty years. Accelerated depreciation lets the VPU deduct the full cost of qualifying assets faster than under standard rules, accelerating cash flow in the early project years. Tax losses are deductible without time limit and become transferable to third parties from the fifth year onward, which functionally creates a market for unused-loss carryforwards. Dividend distributions are taxed at 7%, dropping to 3.5% after seven years. The 7% headline matches Argentina’s standard dividend withholding; the RIGI advantage is the drop to 3.5% and the thirty-year lock that freezes it.

Stack the four benefits together and a qualifying project pays meaningfully less on the income line, captures depreciation faster, has more flexibility on losses, and remits dividends abroad cheaper. Then layer thirty years of stability on top.

The Eight Qualifying Sectors

The regime applies to eight sectors: forestry, tourism, infrastructure, mining, technology, steel, energy, and oil and gas. Within each, sub-categories specify what the qualifying investment looks like.

For Bitcoin-aligned operations, the relevant sector is energy, with a specific eye to generation infrastructure that pairs with Bitcoin mining. Argentina has stranded gas in Vaca Muerta, hydroelectric capacity in the Patagonian south, and underutilized renewable potential across multiple provinces. A $200M energy-and-mining project that builds generation alongside data-center load is, on paper, a strong RIGI candidate.

Mining of Bitcoin itself is not currently named as a qualifying sub-sector under the technology category, and the regulatory architecture treats Bitcoin-mining hosting as an industrial-load question rather than a "tech" question. The right legal frame for a Bitcoin-mining-and-generation deployment is the energy sector with hosting as the off-take, not the technology sector with mining as the product.

Why It Is Not For Most Bitcoiners

The structural mismatch is the threshold. A single Bitcoiner exploring Argentine residency or citizenship is looking at one of three pathways: the rentista visa for verified passive foreign income, the (currently paused) Citizenship by Investment (CBI) framework, or the long-form naturalization route through two years of legal residence.

RIGI sits in a different layer entirely. It is the file your Bitcoin-treasury holding company runs if it is also building a $200M industrial deployment in Argentina. It is not the file you run as the natural-person investor in that company.

Three conflations to avoid.

01 / RIGI is not a residency pathway. Approval grants the VPU a thirty-year stability lock. It does not grant the investor a residency permit. RIGI does carry a separate immigration provision for foreign personnel assigned to qualifying projects, but that is a project-staff residency permit, not a CBI shortcut.

02 / RIGI is not a citizenship pathway. Argentine citizenship runs through Law 346, on a two-year continuous-legal-residence floor. RIGI does not touch that pathway in either direction.

03 / RIGI is a corporate-vehicle benefit, not a wealth-management vehicle. The regime cannot be used to park personal Bitcoin-derived wealth and capture the tax benefits. Qualifying capital must be deployed against a real project in a qualifying sector, with the 40%-in-two-years milestone, and the VPU must operate as a going concern.

Who It Is For

The Bitcoiner profile that should evaluate RIGI seriously is narrow. Industrial-scale Bitcoin mining operations with $200M+ total project capital, paired with energy infrastructure, deploying in qualifying Argentine provinces. Treasury companies with a real Argentine operating layer. Energy companies with Bitcoin-mining off-take built into the project economics from the start.

Outside that profile, the right files are different. Rentista for the Bitcoin earner with structured passive yield. Long-form naturalization for the Bitcoiner who can spend two years in Buenos Aires. CBI when (and if) the framework reopens.

The Principle

Milei’s RIGI is a thirty-year stability lock for industrial-scale investments. It works as advertised. The $200M threshold and the thirty-year horizon do exactly what the regime says they do.

What RIGI does not do is grant citizenship, grant residency, or substitute for either. The Bitcoiners who treat RIGI as an adjacent residency vehicle are reading a tax-stability statute as if it were an immigration statute. The two are not the same file.

Programs change. The programs available today may not exist next year. Every CBI threshold increase in history has been upward. Low time preference does not mean no action. It means making the right move at the right time.

If you want to walk through whether RIGI fits your project, whether the rentista is the right Argentine residency file for your stack, or whether to wait for the CBI framework to reopen, start with the paid Sovereignty Strategy Session. The Session is encrypted, and there is no obligation to proceed beyond it.

Adam Juchniewicz, CEO US Air Force veteran. Bitcoiner since 2020. Licensed agent of The Bitcoin Office of El Salvador.