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January 10, 2024

Argentina to issue 'Bonds for the Reconstruction for a Free Argentina'

  • The Argentine Central Bank will issue the bonds for Argentine entities that have debts for importing of goods and services as of 12 December 2023.
  • The bonds' subscriptions made through 31 January 2024 will be exempt from Impuesto PAIS.

On 22 December 2023, the new Argentine Government issued Decree No. 72/2023 (the Decree) related to the Bonds for the Reconstruction for a Free Argentina (Bonos para la Reconstruccion de una Argentina Libre, in Spanish, abbreviated as BOPREAL).

BOPREALs that the Argentine Central Bank (Banco Central de la Republica Argentina or BCRA) issues to Argentine entities that have cross-border debts for imports of goods with customs entry registration and for services, as of 12 December 2023, may be used as payment — at their technical value — for the cancellation of tax (e.g., income tax or value-added tax) and customs obligations, plus interest and fines. The BOREALs cannot be used to pay Social Security taxes, tax on debits and credits, or certain other taxes.

The BOPREAL subscription in Argentine Pesos is subject to the tax on certain purchases of foreign currency (Impuesto PAIS) at a 0% rate for subscriptions made through 31January 2024 and at the rate applicable to the import for subscriptions made from 1 February 2024 onward.

These measures became effective as from 22 December 2023.

As a complement to this Decree, the BCRA also issued Communication "A" 7925, which clarified some points, including that with the collection of the payment of principal and interest in foreign currency of the BOPREALs, the importer may use the funds deposited in its local account to cancel the liabilities abroad for the import of goods and services that originated the BOPREALs subscription.

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Contact Information

For additional information concerning this Alert, please contact:

Pistrelli, Henry Martin & Asociados S.R.L., Buenos Aires

Ernst & Young LLP (United States), Latin American Business Center, New York

Ernst & Young LLP (United Kingdom), Latin American Business Center, London

Ernst & Young Tax Co., Latin American Business Center, Japan & Asia Pacific

Published by NTD’s Tax Technical Knowledge Services group; Carolyn Wright, legal editor