Novedades
By LFS
Out-of-system dollars: key issues and risks in real estate transactions
The elimination of reporting regimes such as COTI and CITI Escribanos aims to reduce bureaucracy in real estate transactions and boost market activity. In this context, Decree 353/2025 announced the possibility of using so-called “under-the-mattress” dollars to purchase properties, sparking strong interest as well as multiple questions regarding its tax implications.
In an article published by Ámbito on May 27, 2025, Fernanda Laiún, partner at LFS and tax specialist, analyzed the potential effects of the new scheme and warned about the lack of a regulatory framework clearly defining how the measure will be implemented.
“Without specific regulations, many notaries may raise no objections at the time of execution, but taxpayers must be clear about how to justify the origin of the funds,” Laiún noted in the interview.
She also emphasized that the regime does not constitute a formal tax amnesty and that taxpayers should proceed with caution to avoid future tax contingencies.
According to LFS’s analysis, measures of this nature require preventive tax planning and proper documentation of the origin of funds, particularly in transactions involving undeclared dollars. Professional advice is key to ensuring transparency and minimizing risks in the event of future audits.