PAIS Tax: New Refund Regime for Unused Advance Payments 

Which transactions are included?

As established in General Resolution 5765/2025, issued by the Argentine Tax Authority (ARCA), the regime now applies to advance payments of the PAIS Tax that have not been offset, either fully or partially, against tax obligations relating to:

1. Imports of goods declared up to December 12, 2023, for which: 
1.1. The importer did not access the FX market, nor did it subscribe in ARS bonds or securities issued by the Argentine Central Bank denominated in USD.
1.2. The importer did not access the FX market, nor did it subscribe in ARS bonds or securities issued by the Argentine Central Bank denominated in USD and levied the PAIS tax at a 0% rate.
1.3. The importer accessed the FX market or subscribed in ARS bonds or securities issued by the Argentine Central Bank denominated in USD and levied the PAIS tax at a 0% rate, but only for partial payments of the import.

2. Imports of goods declared between December 13, 2023, and November 24, 2024, for which the importer did not access the FX market or did so after the tax expired.

Which are the applicable procedures and timelines?

The Resolution reestablishes the Registry of Import Declarations with Noncomputed PAIS Tax payments in advance. Registration in the system must be completed by submitting the sworn statement DJIP–Affidavit for the refund of PAIS Tax advance payments on imports of goods. The DJIP must be filed between October 16–November 19, 2025 (inclusive).
ARCA will verify the submitted information. If it does not detect inconsistencies, a tax credit will be automatically granted for the refund amount.

How is the sum refunded?

The same way it was the last time, under Resolution 5720. Depending on the total amount, the credit will be paid in 1–24 equal, consecutive, monthly installments. If the refund exceeds ARS 100 million, it will be paid in 24 installments. Each installment will include compensatory interest calculated from the date the DJIP was submitted until the date of payment.
The first installment will be available on December 15, 2025. Later installments will be available within the first five business days of each month.

How can taxpayers use the refund credit?

The credits generated may only be used to pay import duties through the MALVINA System-SIM (identified as Payment Method IV–Payment in Value).

What happens with the refund or reimbursement procedures?

Resolution 5720 establishes that this mechanism is optional and that adhesion implies:
•    waiving the right to pursue other administrative or judicial proceedings with the same purpose, 
•    mandatorily withdrawing any existing administrative or judicial claims by filing Form 408.

Resolution 5765 clarifies that the withdrawal must be filed after the refund claim was accepted in the Registry.