Through the Provision 120/2025published in the Official Gazette, the agency introduced a new scheme of deadlines and notifications which gives greater margin to taxpayers to catch up before being reached by a precautionary measure.
The objective of the measure, as explained by the agency, is to generate “Legal certainty and predictability“In the procedures, recognizing a”paradigm change”In the collection policy, which aims to facilitate voluntary debt cancellation before resorting to judicial embargoes.
What changes with disposition 120/2025?
One of the central points of the regulations is Implementation of a minimum term of 48 hours Between the expiration of the period to present exceptions and the possibility of Arca progressing with a precautionary measure, as an embargo.
This change implies that the Treasury You cannot immediately seize the taxpayer after the expiration of a debt in execution. Now, a Additional and formalized time to allow spontaneous regularizations, without direct judicial intervention.
In addition, the norm includes a exception for cases where the distance between the body’s headquarters and the taxpayer’s domicile exceeds 100 kilometers. In those cases, and with judicial authorization, An early lock can be requestedas long as there is previously notified to electronic fiscal domicile The debt detail. Even so, the taxpayer will have a period of Five days to cancel before the measure is completed.
Arca recovered more than $ 620,000 million with payment plans
The disposition also comes after a series of Intensive fiscal regularization actions. Between January and May 2025, Arca offered a Payment Facilities Plan which allowed to reduce by 66% the capital debt of a specific universe of taxpayers, going from $ 1,788 million at $ 613,853 million.
During that period, the agency sent communications to electronic tax addresses Taxpayers with debts contracted between 2020 and 2024segmenting the notices in three groups:
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Debts equal or greater than $ 20,000,000
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Debts equal or greater than $ 7,000,000
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Debts equal or greater than $ 2,200,000
Thanks to that campaign, Arca recovered $ 622.5 billionthat is to say, 77% of the total estimated as owed In the notified sectors. This result reinforces the organism approach to combine Intelligent fiscal pressure with regularization alternatives to maximize collection without immediately resorting to judicial measures.
A new balance between collection and predictability
Provision 120/2025 represents a sign of change in the official fiscal strategy. By offering more time and procedural clarity, ARCA seeks to improve voluntary compliance without resigning action for action against Moray Taxpayers.
For those who face fiscal executions or seizures, the new regulations offer A key temporal respitewhich can make the difference between conserving the flow of funds and facing financial paralysis.
Source: Ambito
