Argentina: Two steps forward - repealing SIRAs and Import Licenses. One step back - creation of SEDI

Creation of the Register of Commercial Debt for Imports with Foreign Suppliers
27 Dec 2023    3 minute read

In brief

By means of the Joint General Resolution AFIP - Secretariat of Commerce 5466/23 ("RG 5466") and Resolution 1/23 of the Secretariat of Commerce ("Resolution 1") the Import System of the Argentine Republic (SIRA) and the Import Licenses — both automatic and non-automatic — are repealed, respectively. The SIRASEs (for services) and the Single Current Account for Foreign Trade (CCUCE) are also repealed.

This important step toward the total liberalization and standardization of foreign trade is, however, marred by the creation of the Statistical System of Imports (SEDI), which maintains certain practices typical of the SIRAs and which may in the future become — in other hands — a new source of problems for foreign trade operators.

In this sense, a simple repeal of the SIRAs and the licenses, with nothing to replace them, would have been much better. Also of concern is maintaining the Economic and Financial Capacity (CEF) system.

Finally, RG 5466 creates the list of commercial debt for imports with foreign suppliers ("List") as a first step to regularize the debts accumulated during the term of the SIRAs.

Contents

The SEDI

The main features of the SEDI are as follows:

  • All importers must provide, as a sworn statement, the information to be indicated in the microsite "Sistema Estadístico de Importaciones (SEDI)" available on the website of the ADMINISTRACIÓN FEDERAL DE INGRESOS PÚBLICOS (https://www.afip.gob.ar).
  • The declaration made through the SEDI -SEDI declaration- shall be valid for a term of THREE HUNDRED AND SIXTY (360) calendar days, counted as from the date on which it obtains the EXIT status.
  • Once the SEDI declaration has been filed, the AFIP will analyze, based on the information available in its records, the tax situation of the taxpayer and its economic and financial capacity to carry out the operation. This will be done through the CEF System, established by General Resolution No. 4,294 (AFIP). As can be seen, compared with the SIRAs, the intervention of the Secretariat of Commerce in the analysis of the SEDI requests is eliminated.
  • Once the above controls are overcome, the SEDI declaration will become OFFICIALIZED.
  • Otherwise, the MALVINA Information System (SIM) will issue a message indicating the inconsistencies detected. Once corrected, a new SEDI declaration must be registered.
  • The SEDI declaration may be filed and obtain OFFICIALIZED status before the arrival of the goods to the customs territory.
  • At the time of officializing the import destination, the SIM will require the SEDI identification number in the SALIDA status.
  • In order to obtain the SALIDA status, the SEDI declaration must have the authorization of all the agencies whose participation is required by the Foreign Trade Single Window (VUCEA), such as ANMAT, INAL and Lealtad Comercial. These agencies have thirty (30) days to issue their opinion. Otherwise, the SEDI declaration automatically goes to SALIDA status.
  • The SEDI declaration will have a tolerance in the FOB unit value of 7% more or less or in the quantity of 7% more, without limit in less, in relation to those consigned in the corresponding import declaration.
  • A SEDI declaration shall not be required for imports made under the courier regime, samples, donations, and diplomatic franchises, those coming from Tierra del Fuego, and other special cases provided for in RG 5466.
  • SIRA declarations in SALIDA or "CANCELLED" status but registered as of 27 December 2023 will remain in force.
  • The remaining SIRA declarations will be eliminated, and a SEDI declaration may be registered.
  • Any SIRASE application that is not approved as of 27 December 2023 will be without effect.

The Register

  • The Register of Commercial Debt for Imports with Foreign Suppliers is created, in which the parties with commercial debt for imports of goods and/or services prior to 13 December 2023 must register.
  • Importers will have 15 calendar days from 27 December 2023 to complete the debt registration according to the guidelines established in the SEDI microsite, which is available on AFIP's website.
  • The information provided therein shall be considered as a sworn statement and shall be binding. Its falsification and/or adulteration will result in corresponding administrative sanctions.
  • Subjects who have debts with foreign suppliers and have managed to cancel them by means of other mechanisms that do not involve the transfer of foreign currency may be registered in the Registry. The purpose of this is to record total compliance with the payment obligations associated with that operation.
  • Subjects having commercial liabilities for imports who do not make the corresponding declaration in due time and form, or who falsify or adulterate the information provided therein, will not be able to access the mechanisms provided in RG 5466, and their debt will be subject to a subsequent evaluation once the situation has been regularized.

Click here to read the Spanish version.

Contact Information
Esteban Rópolo
Partner
Buenos Aires
Read my Bio
esteban.ropolo@bakermckenzie.com
Victoria Acevedo Freixas
Associate
Buenos Aires
victoria.acevedo@bakermckenzie.com

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