Abstract
Argentina's Régimen de Incentivo para Medianas Inversiones (RIMI), Title XXIII of Ley 27.802, offers small and medium companies two-instalment depreciation of new movable capital goods and value-added tax refunds after three monthly periods, for investments invoiced between March 6, 2026 and May 19, 2028. This paper asks whether The SAVI Group can implement The SAVI Capital Model itself through that regime, with investors from the United States, the European Union and the United Arab Emirates, starting with one tranche of USD 9 million and growing organically to USD 200 million. It finds a lawful route and states its conditions. The small-business registry tests a foreign fund vehicle as an entity, never looking through it to its investors, and caps the assets of investment funds at ARS 3,438 million, about USD 2.24 million, so the portfolio company must register its first RIMI investment before the fund buys control. The test is one controlled company bought and expanded on a running site, held through a Delaware limited partnership under the Qualified Purchaser exemption and advised by a SAVI-owned exempt reporting adviser. On a 1.0% fee on invested capital, 20% carried interest above an 8% hurdle with no catch-up, a lean cost base and two classes, the commercial class receives 18.0% and the catalytic class 8.4%, against 18.4% for the same deal run conventionally; the workforce receives USD 3.14 million over five years. On a ladder to USD 200 million through further RIMI companies, the Régimen de Incentivo para Inversiones Relevantes (RIIR) if Congress enacts it, and the general regime, the pooled return is 13.9% against 19.0%. The sensitivities show that no reduction of the workforce's half buys the investor more than half a point, that cost and size drive the result more than the Model does, and that the investor's upside is capped near the Minimum Return to Capital under the clause of record. A separate offshore vehicle for Sylvanus AI appears only as a hypothetical. The SAVI Group offers the design and promises no return.
The first three papers of the series set out The SAVI Capital Model, applied it to a sovereign and applied it to a USD 300 million fund under Argentina's large-investment regime; this paper names a sponsor. The test tranche buys one running company for about USD 3 million and adds about USD 6 million of new equipment before May 2028, and each company pays half of Net Profit to its people under art. 105 b) of the Ley de Contrato de Trabajo and carries the Model's terms in its charter. The fund's investors as a whole earn 13.1% net against 18.4% for the same deal run conventionally; on the route to USD 200 million the workforce receives about USD 71 million. The paper promises no return.
Fourth paper of the series. The specification of the model is The SAVI Capital Model™: Reform Before Rupture (DOI 10.5281/zenodo.23249969); its sovereign application is The SAVI Capital Model™: Conversion Before Default (DOI 10.5281/zenodo.23703653); its application under RIGI is The SAVI Capital Model™ under RIGI: Deployment Before Statute (DOI 10.5281/zenodo.23927033).
DOI: 10.5281/zenodo.23988759 · Published 5 November 2026 · Version 1.1 · CC BY 4.0 · Zenodo record
How to cite: Vitagliano, S. (2026). The SAVI Capital Model™ under RIMI and RIIR: Proof Before Scale. A Private Equity Fund under Argentina's Régimen de Incentivo para Medianas Inversiones and Régimen de Incentivo para Inversiones Relevantes: the First Tranche, the Sponsor and the Route to USD 200 Million (Version 1.1). The SAVI Group. https://doi.org/10.5281/zenodo.23988759
Fifth paper of the series: The SAVI Capital Model™ in the Southern Cone: Origination Before Capital (9 November 2026) argues that origination, not capital, is the binding constraint on private investment in the Southern Cone. It publishes the screening standard for private companies in Argentina, Chile, and Uruguay and sets out the structure under which capital of any origin can own them under the Model.
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A proposal for discussion. Not an offer of securities and not advice to any investor.