ARCA published General Resolution /25, which reopens the special and optional refund procedure for uncredited advance payments of the PAIS Tax, in line with the recoverability of the PAIS Tax paid through the “advance payment” system for the importation of goods, which -after the rate reduction and subsequent expiration- ended up being an “excess” income.
In this scenario, are all advance payments made until November 24, 2024 that could not credit the mentioned payment against the tax, due to not having accessed the foreign exchange market or having done so after the expiration date of the tax -December 22, 2024.
Cases
Thus, the opening of the recoverability procedure occurs in the following cases:
1. Imports with customs entry registration until /2023, inclusive, regarding which:
2. Imports with customs entry registration between /2023 and /2024, inclusive, whose advance payments of the PAIS Tax could not be credited due to not having accessed the MULC or having done so after the expiration of the tax (/2024).
The mechanism is similar to the previous procedure, with the process extending from October 6, 2025 until November 19, 2025, both inclusive.
Tax credit
Again, it will not allow access to cash money, but will be granted via a tax credit expressed in installments -from 1 to 24- applicable only to the cancellation of import duties.This is highly questionable, since we are talking about advance payments made at least one year ago, to which two more years can be added if we consider the maximum number of installments.The installments begin to be credited starting December 15, 2025.
Furthermore, we remind that an interest in favor of the taxpayer is considered, but it is 0.5% monthly.It goes without saying that this rate does not reflect the current inflation, even though it is declining.
Information channel
As a positive aspect, we must highlight that thehelp channel opened by ARCA for queries or problems in exporting informationwill be enabled from October 6, 2025, inclusive, until 12:00 p.m. on November 20, 2025. This channel was highly used with positive results in the first phase, so we understand it will be replicated again on this occasion.
Finally, this procedure implies the withdrawal of any refund /or repetition procedure filed previously.
The author is a Tax Partner at BDO in Argentina
