The recovery of payments on account of the non -computed country tax has gained preponderance in the world of taxes.
As a review, we remember how the rates applicable to payment on account have evolved, equivalent to 95% of the country tax rate, in accordance with the provisions of the different general resolutions published by the Argentine Treasury.
The variations of the fees and the temporal scope between the date of the import office and the payment to the suppliers through the Mulc, produced excess payments that originated balances in favor in most importers. Likewise, payments have been caused without cause in cases where obligations by means of access to the Mulc have been canceled.
Until a while ago, the only possible way to recover these balances was through the route of the Return application. It is important to note that, amparos have been submitted in both the administrative and judicial instance, and several cases have been known in favor of taxpayers regarding the demand for response by Arca.
On July 7, 2025, General 5720 resolution was issued, establishing a special procedure for the return of these non -computable account payments applicable as of July 8 and until August 22 of the current. This resolution tries to approach the damage of the generation of these balances in favor.
The most important thing to highlight and understand in this procedure is that it is Optional character And the return will not be in cash but a loan to compute in installments to the cancellation of import rights. The amount will vary according to the amount requested in return:
Likewise, in accordance with the Manual issued by the Directorate of Programs and Standards of Customs Procedures of the ARCA on July 8, 2025, the balances recovery in favor of the PAIS Tax of the RG 5720 only applies to the following cases, for the moment:
- Aliquot reduction – Decree No. 777/2025 (Reason A)
- Temporary import and Free Zone – Decree No. 14/2024 (Reason B)
- Price Agreement – Decree No. 433/2023 7 General Resolution No. 5414/2023 (Reason C)
If the option is exercised, it is renounced to request the return of balances in favor through administrative and/or judicial recursive roads.
Since the inflation variable remains relatively stable, it is time to analyze the recoverability of these balances in excess or without cause, also considering that the incidence of taxes affects the competitiveness of companies in the market.
In these cases, it is recommended to evaluate the pros and cons of exercising the option granted by the Treasury, depending on the situation of each importer.
SMS members
Source: Ambito
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