01-12-2025

Through General Resolution No. 5,792 (published in the Official Gazette on November 25, 2025), the Revenue and Customs Control Agency (ARCA) established an optional procedure allowing taxpayers and/or responsible parties with refund requests for national tax credits freely available and linked to foreign trade operations, and/or export rebate payment claims—whether accumulated or officially filed as of October 31, 2025—to request that such amounts be expressed in U.S. dollars.

Application for the Option

To exercise this option, applicants must access (with a Tax ID  Level 3 or higher) the “Option to convert/disclose balances Res. 1834/2025 – MEC” service, available on ARCA’s website.

The option may be exercised from December 5, 2025 through March 1, 2026.

Refund Requests for Freely Available National Tax Credits Linked to Foreign Trade Operations

The option may be exercised in whole or in part for each refund request of freely available credit balances accumulated as of October 31, 2025, provided that the refund request has been:

• Submitted before December 31, 2025, and

   

• Approved and notified before March 1, 2026, and remains unpaid as of that date.

   

If the option is exercised for an amount lower than the approved refund, the payment process for the remaining balance will continue as usual.

Information Verification

The information provided by the taxpayer will be verified by ARCA against data related to the foreign trade operations that originated the withholdings or tax perceptions carried out under regime codes 80, 83, 265, 267, 531, 700, 714, and 864, among others.

Conversion of the Amount

The amount accepted under this option will be converted into U.S. dollars using the Banco Nación Argentina selling exchange rate as of November 18, 2025.

Export Rebate Claims

The option may be exercised for rebate settlements recorded as of October 31, 2025, with “Refund Generated” status and still pending payment when the option is exercised.

Withdrawal of the Option

Taxpayers and/or responsible parties may withdraw their exercised option until March 1, 2026.

Availability of the Credit

As of March 2, 2026, a certificate will be made available showing all credits for which the option was exercised.

As of January 1, 2027, a credit will be generated in the MALVINA Computer System (SIM), enabling taxpayers and/or responsible parties to request its offset against domestic or customs taxes collected by the General Customs Directorate or, alternatively, to request a refund.

For such purposes, the Banco Nación Argentina buying exchange rate of the day prior to the offset or refund shall apply.

General Provisions

By opting into this procedure, the applicant waives any interest accrued from the date the option is exercised on the amount accepted, as well as the right to pursue any other administrative or judicial remedy for the same purpose regarding said amount. It also entails the withdrawal of any action previously initiated for collection of the amount subject to the option.