It is about Electronic Control Actions System (SIACE), A mechanism of communication of the body with taxpayers through the declared electronic domicile. The SIACE sends notifications and requests for reports or inspections and the taxpayer It has certain deadlines to answer them. It was created in May 2023.
Until now anticipated five type of sanctions for breach. But according to the specialist Sebastián Domínguez, CEO of SDC Tax Advisors, Now there will be onealthough this also results in some complexity for taxpayers.
“Through this system, Arca makes notifications of inductions, communications, requirements, inspections, among others, with the aim of achieving compliance with the presentations of affidavits and payments by the taxpayers and responsible,” says Dominguez.
Not all the notes that the taxpayer receives at his electronic fiscal domicile have to be answered on the same day. Some are usually inductions. In this case of communications trafficking in which Arca tells the taxpayer that he has suspicions that he has undeclared assets, which, for not constituting a legal intimation, is not necessary to respond.
“In the case that a response to the notification must be provided, it will indicate the deadline to answer. The resolution establishes that the term will be between 3 and 15 business days Administrative, ”explains the taxpayer.
Through the Resolution 5660/2025, ARCA makes important changes eliminated 4 of the 5 sanctions for taxpayers:
- Eliminates framing in a different category from the one in the Risk Profile System (SIPER).
Previously, a change of category in the SIPER implied greater risk of inspection, less fees and higher rates in financing plans, in addition to greater controls in certain tax return procedures, among others.
- Eliminates the exclusion or suspension of the special tax records that make up the “registration system” or tax records by Arca.
For example, Arca could suspend a company in the registry as a importer/exporter and that it could not perform such operations.
- Eliminates the impossibility of issuing class “A” invoices.
The measure forced taxpayers to issue “M” class invoices, which could lead to 100% VAT withholdings, severely affecting the liquidity of companies.
- Eliminates consideration for valuation in CEF (financial economic capacity system)
Before, the CEF assessment affected the approval of SIRA and SIRASE statements for imports. However, since January 2024, CEF is no longer taken into account for imports.
What is the only planned sanction
The penalty that will be standing is that Arca can limit a cuit, That is, put taxpayer restrictions to make charges or issue a certain type of invoice, such as List of non -reliable that are not allowed to receive charges for transfers or QR codes, among others.
In fact, the deputy Ricardo López Murphy presented a couple of weeks ago a draft statement for Arca to report the criteria he uses to send to the list of non -reliable to certain cuits.
Among the claims to the body are the following:
- Inform how many taxpayers are currently the unique disabled tax identification code and/or the issuance of restricted sales vouchers by Ark’s decision.
- Inform the reasons why the disqualification of the CUIT and/or restriction for the issuance of sales receipts in each case has been arranged.
- Inform the reasons that justify at least 80% of cases, indicating how many cases correspond to each group of reasons.
- Inform the breakdown by type of taxpayer considering the following categories: (i) human persons, (ii) collective entities (indicate type), (iii) responsible for simplified regime, (iv) responsible for registered and (v) exempt subjects
- Inform what is the historical evolution of the number of cases in the last five years.
- Inform if studies have been carried out on the economic impact of these disqualifications and restrictions on affected companies and workers. In your case, inform conclusions.
- Inform the objective criteria on which the ARCA is based to determine the disqualification of the CUIT or restriction to the issuance of sales vouchers.
- Inform what are the parameters that are considered to differentiate a minor breach, from a higher scale evasion maneuver, to determine the disqualification of the CUIT or restrictions on the issuance of sales vouchers.
- Inform if other preventive measures are taken before reaching the disqualification of the CUIT or the restriction to the issuance of sales vouchers.
- Inform what is the internal evaluation procedure before applying these measures.
- Inform what are the instances of control or supervision within the body.
Source: Ambito
