PAIS Tax: New Refund Regime for Unused Advance Payments

Through General Resolution 5720/2025, published in the Official Gazette on July 7, 2025, the Argentine Tax Authority (ARCA) has introduced an optional refund mechanism of certain advance payments of the PAIS Tax (Impuesto Para una Argentina Inclusiva y Solidaria) that have not been offset against obligations under said tax.

 

Which transactions are included?

This regime applies to advance payments of the PAIS Tax that have not been offset, either fully or partially, against tax obligations relating to:
 

• Decree 433/2023, regarding price agreement schemes for the domestic market coordinated with the Secretariat of Commerce.
• Decree 14/2024, regarding imports of goods under a Certificate of Typification for Free Trade Zones.
• Decree 777/2024, regarding reduction of the PAIS Tax rate applicable to:
   
  • the acquisition abroad or from certain non-resident parties of freight and other transportation services related to import or export of goods,
  • imports of goods classified under the Mercosur Common Nomenclature.

The recitals of the Resolution state that the scope of the refund mechanism may be expanded in a later phase to include additional transactions, subject to specific conditions, requirements, and procedures to be defined.

 

Which are the applicable procedures and timelines?

The Resolution creates 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 July 8— August 22, 2025 (inclusive).

ARCA will verify the information submitted. If it does not detect inconsistencies, a tax credit will be automatically granted for the refund amount.

 

How is the sum refunded?

Depending on the total amount, the credit will be paid in 1 to 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 September 8, 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.