Through General Resolution No. 5,765/2025, published in the Official Gazette on 25 September 2025, the Revenue and Customs Control Agency (abbreviated ARCA, in Spanish) has established Phase 2 of the special procedure for the refund of payments on account of the Impuesto PAIS (i.e., paid with the import of goods) that have not been fully or partially computed and that correspond to:

1. Imports of goods with customs entry registration through 12 December 2023 for which:
1. There was no access to the local Official Foreign Exchange Market (MULC in Spanish), and no bonds or securities subscribed in pesos (i.e., offered to investors in pesos) were issued in US dollars by the Central Bank.
2. There was no access to the MULC, and the entities purchased, in pesos, bonds or securities issued by Central Bank that were subject to Impuesto PAIS at a rate of 0%.
3. There was partial access to the MULC, or bonds or securities that the Central Bank issued in US dollars (subject to the PAIS Tax at a 0% rate) were partially subscribed in pesos.
2. Imports of goods with customs entry registration from 13 December 2023 to 24 November 2024, inclusive, for which the advance payment of the Impuesto PAIS could not be credited due to lack of access to the MULC or because access was obtained after the expiration of the tax's validity.

To comply with the above requirements, the regulation reopens the "Registry of import clearances with payments on account of the Impuesto PAIS not computed" (the Registry), created under General Resolution No. 5,720. The Registry will be available on the ARCA's website.

Importers must enter the Registry and complete the Affidavit for the Refund of Payments on Account of the Impuesto PAIS on Imports of Goods (DJIP in Spanish) from 6 October 2025 to 19 November 2025, both dates inclusive.

Implications

It is important to note that the procedure established by this General Resolution, as with the previous General Resolution 5,720, is optional, and its use entails waiving the right to initiate any other administrative or judicial proceedings for the same purpose. (For background, see EY Global Tax Alert, Argentine Tax Authorities implement procedure to recover Impuesto PAIS payments, dated 8 July 2025.) If proceedings have already been initiated, the importer must withdraw the administrative and/or judicial action to access the special procedure. This withdrawal must be made once the system has accepted the refund request in the Registry.

Finally, the provisions of General Resolution No. 5,720 will apply to various matters, including the generation of the credit to be refunded, its use for the cancellation of import duties, and the installment refund schedule based on previously published amounts. The first installment under Phase 2 will be due by 15 December 2025, and the remaining installments will be paid within five business days of each calendar month.