In focus

The main aspects of General Resolution 5720/2025 are as follows:

1. Included transactions: The refund procedure for credit balances provided in General Resolution 5720/2025 only applies to credit balances generated in transactions covered by the following decrees:

• Decree 433/2023: entities with price agreements with the former Secretariat of Commerce.
• Decree 14/2024: imports under the Free Trade Zone Typification Certificate.
• Decree 777/2024: uncredited advance payments following the reduction of the tax rate to 7.5%.

2. Excluded transactions: It is noted that the regulation does not cover all scenarios that may have generated credit balances in the PAIS tax. For example, it does not include taxpayers who generated credit balances in the PAIS tax due to the inability to credit advance payments as a result of the repeal of the tax prior to the occurrence of the taxable event, or those who, despite making the advance payment, never triggered the taxable event of the PAIS tax because they ultimately canceled their commercial transactions without accessing the MULC (e.g., through bonds swap transactions). However, the regulation provides that, at a later stage, the procedure will be enabled for credit balances arising from other sources not expressly contemplated in this regulation, although it does not establish specific deadlines or procedures for those purposes.
3. Procedures: The Registry of Import Declarations with Uncredited Advance Payments of the PAIS Tax ("Registry") is created. Importers must log in with their tax code to the service "Registry of import declarations with uncredited advance payments of the Tax for an Inclusive and Solidary Argentina — PAIS" on the ARCA website and submit the refund affidavit. The submission period for the affidavit will run from 8 July to 22 August 2025, inclusive. Submission implies automatic registration in the Registry. If no inconsistencies are detected, a credit will be automatically generated in the MALVINA system, which may only be used for the cancellation of import duties, as well as an identifier as Payment Method IV (Value Entry), based on the amount to be refunded, according to the following scheme:

4. Installments/interest: The installments on the principal to be refunded will be monthly, equal and consecutive, and will include an interest rate of 0.5% per month, calculated on each installment from the date of submission of the refund affidavit until the payment date of each installment, both dates inclusive. Accredited interest not used through this procedure will not be eligible for refund. The first installment will be available on 8 September 2025, and the remainder within the first five business days of each calendar month.
5. Voluntary application: The procedure is optional. Its use implies the waiver of any other administrative or judicial remedy for the same purpose, and, if already initiated, such actions must be withdrawn using Form F. 408/PD through the "Digital Submissions" service.

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