Reinstatement of the procedure for refunding advance payments of the PAIS Tax – Barreiro

Reinstatement of the procedure for refunding advance payments of the PAIS Tax: General Resolution ARCA 5765/2025

The Tax Collection and Customs Control Agency (ARCA) established, through General Resolution 5765/2025, the reinstatement of the special procedure for the refund of advance payments of the PAIS Tax that could not be credited to import operations.

The measure seeks to channel the credit balances generated in two scenarios:
(i) imports carried out up to December 2023, in the context of foreign exchange restrictions and the use of BOPREAL securities taxed at 0%, and
(ii) subsequent operations performed before the termination of the advance payment regime in November 2024.

Covered operations

General Resolution 5765/2025 provides that the special refund procedure will cover the following operations:

Imports with customs entry registration up to and including 12/12/2023, for which:

1.1 Access to the Single Free Exchange Market (MULC) was not obtained, nor were bonds or securities issued in U.S. dollars by the BCRA subscribed in pesos.

1.2 Access to the MULC was not obtained, but bonds or securities issued in U.S. dollars by the BCRA, subject to the PAIS Tax at a 0% rate, were subscribed in pesos.

1.3 Partial access to the MULC was obtained, or bonds or securities issued in U.S. dollars by the BCRA, subject to the PAIS Tax at a 0% rate, were partially subscribed in pesos.

Imports of goods with customs entry registration from 12/13/2023 to 11/24/2024, inclusive, for which:

The advance payment of the PAIS Tax could not be credited because access to the MULC was not obtained, or was obtained after the termination of the tax’s validity.

Imports with customs entry registration between 12/13/2023 and 11/24/2024

This includes operations whose advance payments could not be credited because access to the exchange market did not occur or occurred after the end of the advance payment regime (11/25/2024), the date on which the possibility of crediting such payments ceased.

Procedure and conditions for requesting a refund

The resolution reinstates the “Registry of import clearances with uncredited advance payments of the PAIS Tax,” created by RG 5720.

Registration in said Registry is formalized through the Sworn Statement for the Refund of Advance Payments of the PAIS Tax for Imports of Goods (DJIP).
Filing period: from 10/6/2025 to 11/19/2025.
Filing the DJIP implies automatic registration in the Registry.
ARCA will verify the information declared and, if no inconsistencies are found, will generate the corresponding refund credit.

Refund mechanism

The refund is governed by the same terms as RG 5720:

The credit will be refunded in 1 to 24 equal, consecutive monthly installments, depending on the amount.
When the balance in favor exceeds ARS 100 million, the refund will be made in 24 installments.
Installments will accrue compensatory interest, calculated from the filing of the DJIP until the payment date.
The first installment will be available on 12/15/2025, and the remaining ones within the first five business days of each month.

Use of credits

The refunded amounts may be used exclusively for the payment of import duties through the MALVINA IT System (Payment Method IV – Entry in Securities).

Relation to other administrative or judicial proceedings

Adherence implies waiving the right to initiate other recovery actions for the same purpose.

Likewise, it requires the withdrawal of any proceedings already initiated through the filing of Form 408.
The withdrawal must be carried out once the refund request has been accepted in the Registry.