12 May 2025

Argentine Central Bank allows subscription of BOPREAL Series 4 to pay remaining debts

  • Communications "A" 8233 and "A" 8234, which the Argentine Central Bank issued on 30 April 2025, allow the subscription of Bonds for the Reconstruction for a Free Argentina (BOPREAL) Series 4 to pay remaining debts with foreign parties.
  • Debts eligible for BOPREAL subscription include imports of goods, profits and dividends to non-resident shareholders and interest on commercial and financial debts with related parties.
  • BOPREALs will be denominated in US dollars with an annual interest rate of 3%, payable quarterly or semi-annually.
  • This measure provides taxpayers with a mechanism to settle outstanding debts with foreign parties under the prior foreign exchange regime.
 

On 30 April 2025, the Argentine Central Bank (BCRA) issued Communication "A" 8233 and Communication "A" 8234, which allows the subscription of Bonds for the Reconstruction for a Free Argentina (BOPREAL) Series 4 to pay remaining debts with foreign parties (For background, see EY Global Tax Alerts, Argentina to issue 'Bonds for the Reconstruction for a Free Argentina', dated 10 January 2024 and Argentine Central Bank allows subscription of BOPREAL to pay profits, dividends to nonresidents, dated 03 May 2024)

BOPREALs may be subscribed for up to the amount owed at the date of subscription by those who have debts for:

  • Imports of goods with customs entry registration until 12 December 2023
  • Debts for services rendered by non-residents or accrued up to 12 December 2023
  • Debts for profits and dividends of nonresident shareholders
  • Interest due up to 4 July 2024 for commercial debts for imports of goods and services with related parties
  • Interest due up to 31 December 24 on financial debts with related parties
  • Overdue principal on financial debts with related parties

BOPREALs will be denominated in US dollars and accrue an annual interest rate of 3%, which may be payable quarterly or semi-annually in US dollars, to be defined when the tender is announced. The first tender is scheduled for mid-May.

At the time of subscription, documentation must be available to prove the debt exists, the amount owed and to verify that, among other things, the operation has already been declared.

Implications

This new measure aims to normalize the foreign exchange regime in line with the measures taken by the government to eliminate most remaining foreign exchange controls (For background, see EY Global Tax Alert, Argentina eliminates most remaining Foreign Exchange controls, dated 15 April 2025.

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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

Document ID: 2025-1039