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

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. Fourth paper of the series. The Model's specification 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). Version 1.1, November 2026 (first published 5 November 2026 as Version 1.0). Executive summary and full text in one file: 36 pages, 32 references.

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Zenodo (CERN European Organization for Nuclear Research)
Published
2026-11-05
DOI
https://doi.org/10.5281/zenodo.23985854
Primary Topic
Private Equity and Venture Capital
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article
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article

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

Santiago Vitagliano
Zenodo (CERN European Organization for Nuclear Research)
Private Equity and Venture Capital
article

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

Santiago Vitagliano
article en

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. Fourth paper of the series. The Model's specification 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). Version 1.1, November 2026 (first published 5 November 2026 as Version 1.0). Executive summary and full text in one file: 36 pages, 32 references.

Zenodo (CERN European Organization for Nuclear Research)
Savi (United States) (US)
Openalex Percentile: Top 11%
Private Equity and Venture Capital
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