The Argentine Thread

Guide · 5. FX and capital controls

BOPREAL: the BCRA bonds for importers and dividend arrears

Last verified: 27 Oct 2026 · Status: Changing

  • What BOPREAL is. "Bonos para la Reconstrucción de una Argentina Libre" (BOPREAL) are notes of the Banco Central de la República Argentina (BCRA), denominated and paid in US dollars but subscribed in pesos at the official reference rate of Com. A 3500. The BCRA created the instrument by Com. A 7918 of 13 December 2023 for importers with unpaid debts, as a way to spread over time its obligation to give FX market access for the stock of old import debt (Decree 72/2023, recitals). The legal basis for the BCRA to issue bonds is art. 18(i) of its Charter (Decree 72/2023, recitals).
  • Four series. Series 1 (BPO27, 5% a year, matures 31 October 2027, split into strips 1A, 1B, 1C and 1D, three of which carry a holder put payable in pesos), Series 2 (BPJ25, no interest, twelve monthly instalments, SMEs only, matured 30 June 2025), Series 3 (BPY26, 3% a year quarterly, matured 31 May 2026) and Series 4 (BPO28, 3% a year, bullet maturity 31 October 2028, split into strips 4A and 4B). Terms come from Com. B 12695 (Series 1 to 3) and Com. B 12999 (Series 4).
  • Who could subscribe. Importers of goods with customs entry, and importers of services provided or accrued, up to 12 December 2023 (FX points 4.4 and 4.5); companies with dividends pending payment to non resident shareholders and non residents holding peso dividends collected since 1 September 2019 (point 4.6, from Com. A 7999 of 30 April 2024); and, for Series 4, debtors of overdue principal and interest owed to related parties that need BCRA prior approval (point 4.7, from Com. A 8234 of 30 April 2025).
  • The trade off. Subscribing converts a blocked peso debt into a US dollar claim on the BCRA. In exchange the company signs a sworn statement that it will not access the FX market to pay that same debt except by using the dollars it collects from the BOPREAL (points 4.6.1.4.iii and 4.7.4.3). The bonds can be held, sold for dollars (with relief from the 90 day "cross restriction"), sold by cable to a third party abroad such as the foreign creditor or parent, or, for strips 1A, 1B and 1C only, handed to ARCA to pay federal taxes (Decree 72/2023; RG ARCA 5469 and 5675).
  • Is it still open? The BCRA called the auction of 16 July 2025 "la última licitación de BOPREAL Serie 4" (Com. B 13014). No later BOPREAL auction call appears among BCRA "B" communications up to Com. B 13275 of 16 October 2026 (probe note in the sources). The FX rules allowing subscription (points 4.4 to 4.7) remain in the consolidated text at 14 September 2026, but with no instrument on offer, primary subscription is not available today unless the BCRA calls a new auction (unconfirmed).
  • Interaction with the dividend easing. Since 14 April 2025, profits from audited annual statements of fiscal years started on or after 1 January 2025 can be paid abroad without prior approval (point 3.4.4.1, Com. A 8226, point 6). Profits from earlier years ("legacy" or "trapped" dividends) still need prior approval or another route; BOPREAL was the BCRA's offered exit for them, and existing holders can still pay legacy dividends with BOPREAL collections (points 3.4.4.2 and 4.8.1.3). We found no BCRA communication in 2026 (A 8330 to A 8497 checked) that further eases legacy dividends (unconfirmed).

Who should read this page.

  • Finance directors of Argentine subsidiaries that hold BOPREAL from 2024 or 2025 and must decide whether to hold, sell, exercise the put or pay taxes with them.
  • Foreign parents with dividends declared from pre 2025 profits that still sit in pesos in Argentina.
  • Importers that still carry old (pre 13 December 2023) commercial debt or related party interest.
  • Advisers who need the exact rule, the series terms and the open questions in one place.

Peso amounts are converted at the dólar MEP (bolsa) selling rate of ARS 1,563.90 per US$ on 23 Oct 2026 (source: dolarapi.com, MEP quote). Conversions are indicative and move daily.

Key rules

1. Legal basis and the BCRA framework

  • Creation. Com. A 7918 (13 December 2023, circular REMON 1-1103) allowed the BCRA to offer US dollar notes "con opción de rescate" to importers of goods and services with unpaid imports, up to the unpaid amount. Framework terms: maximum term to 31 October 2027; subscription in pesos at the Com. A 3500 reference rate of the business day before the auction; payment in US dollars at amortisation, or through early redemption options in favour of holders settled only in "pesos dollar linked"; interest on a 30/360 basis at a maximum of 5% a year, payable quarterly or half yearly in dollars; registrar and settlement agent CRyL; secondary trading on BYMA/MAE and Euroclear to be decided in each auction notice.
  • Mechanics of the put in the framework. Com. A 7918 foresees that the redemption rights will be "stripped" into separate instruments one month before each exercise date, that the strips pay dollars at maturity or can be exercised against dollar linked pesos at the BCRA on the option date, and that the holder must give notice 5 business days before the option expires. The actual Series 1 notice set different operational details (strip date 1 March 2024; exercise through a SIOPEL wheel with T+2 settlement), see section 2. Where the framework and the notice differ, the notice governs the series (unconfirmed).
  • Series 4 framework. Com. A 8233 (30 April 2025, REMON 1-1128) allowed a Series 4 for the persons in FX points 4.4, 4.5 and 4.6 and for debtors of overdue principal and interest owed to related parties: maximum term 31 October 2028; interest at a maximum of 3% a year on 30/360; subscription in pesos at the Com. A 3500 rate of the auction date or the previous business day; payment in dollars or, for redemption options, in dollar linked pesos.
  • Series terms. The detailed terms of Series 1, 2 and 3 were announced in Com. B 12695 (22 December 2023) and repeated, with amounts and dates, in each auction call (Com. B 12697 to B 12810). Series 4 terms are in Com. B 12999 (10 June 2025), B 13011 and B 13014.

2. The four series

Series 1 (BPO27). Issued 5 January 2024 (Com. B 12697). Maturity 31 October 2027. Amortisation in two instalments of 50% each on 30 April 2027 and 31 October 2027, in dollars. Interest 5% nominal annual, 30/360, payable on 31 October 2024, 30 April 2025, 31 October 2025, 30 April 2026, 31 October 2026, 30 April 2027 and 31 October 2027. Placement price at par. BCRA call: the BCRA may redeem early, in whole or in part, on any interest date, paying dollars. Minimum denomination VNO US$ 100 and multiples of US$ 10 (US$ 1 for strips 1A to 1C after the strip). Listed on BYMA/MAE, tradable through Caja de Valores and Euroclear; each strip gets its own code. Argentine law (Com. B 12695, section A).

The Series 1 strips. On 1 March 2024 each Series 1 bond was split into four independent instruments with the same terms plus holder put options (Com. B 12695):

Strip Share of original face value Holder put (early redemption) Put payable in
1A 20% From 30 April 2025 to maturity Pesos at Com. A 3500 of the exercise day
1B 20% From 30 April 2026 to maturity Same
1C 30% From 30 April 2027 to maturity Same
1D 30% None Not applicable

The put is exercised through a SIOPEL wheel created for that purpose, settles T+2 at the Com. A 3500 rate of the day of exercise, and the bonds must be deposited in CRyL the day before (Com. B 12695). In plain terms: the holder of 1A or 1B can today convert face value into pesos at the official reference rate; the holder of 1C will be able to from 30 April 2027; 1D must be held to maturity or sold.

Series 2 (BPJ25). First issued 16 February 2024 (Com. B 12736). Matured 30 June 2025. No interest. Twelve monthly instalments on the last calendar day of each month from 31 July 2024: eleven of 8.33% and a last one of 8.37% of original face value. BCRA call on any amortisation date. Subscribers: only SMEs ("MiPyME") registered in the "Padrón de Deudas Comerciales con el Exterior", one bid per CUIT. Allocation if oversubscribed: priority up to the first VN US$ 500,000 per company, the rest pro rata (Com. B 12736, B 12739, B 12746). Maximum issue VN US$ 2,000 million. Com. B 12695 had said Series 2 would be transferable but not listed; the auction calls of February 2024 instead say it would be listed on BYMA/MAE and tradable through Caja de Valores and Euroclear (Com. B 12736, B 12746). The later notices are the operative terms. Series 2 has been fully repaid by its terms; whether the BCRA paid every instalment on time is not in the sources (unconfirmed).

Series 3 (BPY26). First issued 7 March 2024 (Com. B 12750). Matured 31 May 2026. Interest 3% nominal annual, quarterly, 30/360, payable from 31 August 2024 to 31 May 2026. Amortisation in three quarterly instalments of 33%, 33% and 34% on 30 November 2025, 28 February 2026 and 31 May 2026. BCRA call on any interest date. Listed on BYMA/MAE. Subscribers: at first, importers registered in the Padrón (Com. B 12750); from the call of 3 May 2024, any importer with pre 12 December 2023 debts and companies with dividends pending to non resident shareholders and non residents holding peso dividends collected from 1 September 2019 (Com. B 12795, B 12802, B 12810). Maximum VN US$ 3,000 million.

Series 4 (BPO28). Issued 24 June 2025 (Com. B 12999). Maturity 31 October 2028, principal paid in full at maturity in dollars. Interest 3% nominal annual, 30/360, payable on 31 October 2025, 30 April 2026, 31 October 2026, 30 April 2027, 31 October 2027, 30 April 2028 and 31 October 2028. Placement at par. Strip on 30 September 2025 into:

Strip Share of original face value Holder put Settlement
4A 1/3 From 30 April 2028 to maturity T+1, pesos at Com. A 3500 of the exercise day
4B 2/3 None Not applicable

Minimum denomination VNO US$ 100 and multiples of US$ 10 (US$ 1 after the strip). Listed on BYMA/MAE and tradable through Caja de Valores and Euroclear. Unlike Series 1 to 3, the Series 4 notice contains no BCRA early redemption clause (Com. B 12999). Subscribers: legal entities ("personas jurídicas") within FX points 4.4, 4.5 and 4.6, and debtors of overdue related party principal and interest (Com. B 12999). Note that Series 4 is open to "personas jurídicas" only, while point 4.6.2 also covers non resident individuals; whether a non resident individual could subscribe Series 4 under 4.6.2 is not resolved in the sources (unconfirmed). Maximum VN US$ 3,000 million.

3. Who could subscribe: the FX eligibility rules (Section 4 of "Exterior y Cambios")

The rules sit in Section 4 of the BCRA consolidated text "Exterior y Cambios" at 14 September 2026 (last communication A 8481).

  • Point 4.4: importers of goods. Up to the unpaid debt for imports with customs entry registered up to 12 December 2023. The subscribing bank needs certificates of the unpaid amount from the bank(s) that follow the customs entries in the BCRA tracking system SEPAIMPO, which must check that the debt qualifies under point 10.2.4, is declared in the last survey already due ("Relevamiento de activos y pasivos externos"), meets point 10.3.2.1 except item viii), that the client meets points 3.16.1 to 3.16.4 (3.16.3 only for clients that are not resident individuals), and that there is a sworn statement that the debt is unpaid (4.4.1 to 4.4.5). The bank books a sale ticket ("boleto") under concept code B26 for the BOPREAL face value allotted, with the customs entry number. The issuing bank must deduct the certified amount from the residual FX access for that entry in SEPAIMPO, and restore any part not allotted (Com. B 12695).
  • Point 4.5: importers of services. Up to the unpaid debt for services provided or accrued up to 12 December 2023, qualifying under point 13.1.2 (second paragraph), declared in the survey, with points 3.16.1 to 3.16.4 met and a sworn statement that the debt is unpaid and the mechanism not used before. Concept code S33.
  • Point 4.6.1: dividends pending payment. A resident company may subscribe up to the peso amount of profits and dividends pending payment to non resident shareholders under the shareholders' meeting distribution. Requirements: documents showing the dividend comes from closed and audited balance sheets (4.6.1.1); declaration in the last survey due (4.6.1.2); points 3.16.1 to 3.16.4 (4.6.1.3); and a sworn statement signed by the legal representative or an attorney with sufficient powers that the dividends are pending, the mechanism has not been used for them, and the company will not have FX market access to pay the equivalent of that debt except through a swap or arbitrage of BOPREAL dollar collections (4.6.1.4). Concept code I09. Point 3.4, final paragraph, adds a condition: the dividends must be ones subject to BCRA prior approval. Profits that already qualify for free access (for example under point 3.4.4.1) therefore do not need, and do not fit, this route.
  • Point 4.6.2: peso dividends already collected by non residents. A non resident who collected dividends in pesos in Argentina since 1 September 2019 and never sent them abroad may subscribe up to that peso amount adjusted by the latest CPI available at subscription. The resident company that paid must meet points 3.16.1 to 3.16.4; the non resident signs a sworn statement (funds received in its local account since 1 September 2019 and never remitted; mechanism not used before; no FX access to repatriate that equivalent except through BOPREAL collections). The ticket is booked in the name of the company that paid the dividend under code P21 (4.6.2.1 to 4.6.2.3).
  • Point 4.7: overdue related party debts. Debtors that need BCRA prior approval under points 3.3.3 and 3.5.6 may subscribe up to the amount owed at subscription for (i) compensatory interest due up to 4 July 2024 on commercial import debts with related parties, (ii) compensatory interest due up to 31 December 2024 on financial debts with related parties, and (iii) overdue principal of financial debts with related parties. Same pattern of checks and sworn statement (4.7.1 to 4.7.4). Codes I12, I13 and P28. Origin: Com. A 8234 (30 April 2025).

4. What the subscriber gives up: the FX waiver

Under 4.6.1.4.iii, 4.6.2.3.iii and 4.7.4.3 the client acknowledges it will not access the FX market to pay (or repatriate) the equivalent of the debt for which it subscribed, except through a swap or arbitrage with funds in a local account that come from foreign currency collections of BOPREAL principal and interest. The importer statements in 4.4 and 4.5 are worded differently (debt unpaid; mechanism not used), but the BOPREAL subscription is booked against the debt (codes B26 and S33) and, for goods, deducted in SEPAIMPO (Com. B 12695), so the effect is the same: that slice of debt has been "registered" as paid through BOPREAL. In short, the bond replaces the right to buy dollars for that debt. A company that sells its BOPREAL below par has crystallised the loss; it cannot then buy the shortfall in the official market for the same debt.

5. Using BOPREAL collections

  • General rule (point 4.8.1). Clients may access the FX market through a swap or arbitrage of local account funds that come from BOPREAL principal and interest collected in foreign currency, to pay: eligible goods import debts (4.8.1.1); eligible services debts (4.8.1.2); eligible dividends under 4.6.1 (4.8.1.3); repatriation of non residents' portfolio investment from peso dividends under 4.6.2 (4.8.1.4); and principal and interest of eligible related party debts under 4.7 (4.8.1.5). Payments of eligible goods and services debts through the local currency system (SML) using those funds are also covered.
  • Mirrors in other sections. The same exit appears in point 3.4.4.2 (dividends), 3.5.6.5 (related party financial debt), 3.13.1.14 (non resident repatriation of peso dividends), 3.14.5 (swaps and arbitrage not linked to inflows) and 10.11.4 (goods registered up to 12 December 2023).
  • An open question on secondary market holders. Point 3.4.4.2 is worded broadly: access for dividends where "the client carries out a swap or arbitrage with funds deposited in a local account and originating in foreign currency collections of principal or interest of BOPREAL". Unlike 4.8.1.3, it does not say the dividends must have been eligible under 4.6.1, nor that the bonds must come from a primary subscription. Read literally, a company that bought BOPREAL in the secondary market and later collects coupons or principal could argue it may use those dollars for any dividend that meets points 3.4.1 to 3.4.3. The BCRA has not published an interpretation on this point in the sources, and banks may read 3.4.4.2 together with 4.8.1.3 (unconfirmed). Do not rely on it without the bank's written confirmation.

6. Selling BOPREAL: the 90 day relief and cable to third parties

  • The 90 day cross restriction. A company that buys dollars in the official market normally declares that in the previous 90 days, and undertakes that in the following 90 days, it has not and will not sell securities for foreign currency in Argentina, transfer securities to foreign depositaries, and so on (points 3.16.3.1 and 3.16.3.2; detail in Exchange controls).
  • BOPREAL relief. Sales of BOPREAL for foreign currency in Argentina or abroad, and transfers of BOPREAL to foreign depositaries, are ignored for those statements up to the amount acquired in the primary subscription, by those who took part in it (point 3.16.3.6.iv; point 4.8.2, first paragraph). A secondary market buyer does not get this relief.
  • Cable to a third party abroad. Normally, a company selling securities for dollars must collect on its own local account or its own foreign account (points 4.3.2.1 and 4.3.2.2). A primary subscriber under 4.4, 4.5, 4.6.1 or 4.7 may instead sell its BOPREAL against cable to a third party's account abroad, provided the account is not in a jurisdiction that does not apply, or insufficiently applies, the FATF recommendations (points 4.3.2.3 and 4.8.3; origin Com. A 7940 of 11 January 2024 and Com. A 7999, point 1.4). This lets a subsidiary sell the bonds and have the dollars paid directly to the foreign supplier, lender or parent. The 4.6.2 subscriber (non resident with peso dividends) is not listed in 4.3.2.3; it is itself the foreign party, so the point matters less.
  • Loss compensation for importers. An importer that sold primary BOPREAL (4.4 or 4.5) for foreign currency abroad below face value may, for sales and transfers made from 1 April 2024, sell other securities against cable to third parties, and leave them out of the 90 day statements, up to the difference between the face value and what the BOPREAL sale yielded (points 4.3.2.3 second paragraph, 4.8.2 second paragraph, 4.8.3 second paragraph; origin Com. A 7935 point 4 as corrected by Com. C 96983, and Com. A 7952 point 2). This was designed to let importers make the foreign creditor whole. It does not extend to the dividend or related party subscribers.
  • Repos. If a primary subscriber sells BOPREAL under a repurchase agreement, the initial sale is ignored for the 90 day statements, it does not open the "difference" allowance, and once the client recovers the bonds they keep their primary subscription treatment (point 4.8.6; origin Com. A 8055 of 28 June 2024).

7. The Series 1 "50%" and "25%" windows

Clients that subscribed Series 1 before 31 January 2024 for at least 50% of their total eligible pending debts under 4.4 and 4.5 may pay principal of the remaining eligible debts (for which no BOPREAL was subscribed) when: the total paid this way does not exceed 5% of the Series 1 subscribed (4.8.4.1); or the payment is matched by settlement of the same amount of deferred export proceeds due from 1 March 2025, with a monthly cap of 10% of the eligible debts not covered by BOPREAL (4.8.4.2); or it is matched by settlement of export prefinancing to be cancelled with shipments whose proceeds were due from 1 March 2025, up to 10% a month of the advances used (4.8.4.3, with a sworn statement that BCRA approval is needed to cancel those advances early). Clients that subscribed at least 25% may pay up to 50% of the amount of such export advances settled at the same time, also capped at 10% a month (4.8.5). The bank needs a sworn statement with the Series 1 amount and the eligible debts (4.8.4 and 4.8.5, closing paragraphs; points 10.11.5 and 10.11.6). Origin: Com. A 7925 point 3, amended by Com. A 7935 (deadline moved from 31 December 2023 to 31 January 2024) and replaced by Com. A 7941 (11 January 2024). The BCRA reminded subscribers that these extra benefits and the 0% PAIS rate expired on 31 January 2024 (Com. B 12727, B 12730).

8. Paying federal taxes with Series 1 strips

  • Decree 72/2023 (BO 22 December 2023), art. 1: BCRA bonds issued under art. 18(i) of its Charter for those with import debts (goods registered, or services effectively provided, up to 12 December 2023), issued from the decree's entry into force up to 31 March 2024 and expressly accepted by the tax authority, may be given in payment ("dación en pago") of tax and customs obligations administered by AFIP (now ARCA), with interest, fines and accessories. Excluded: social security contributions; health insurance contributions; mandatory life insurance; workers' compensation insurer premiums; the tax on bank debits and credits; and obligations as withholding or collection agent or as substitute or jointly liable taxpayer. The instruments are freely transferable, so a buyer in the market can also use them.
  • Valuation and caps (Decree 72/2023 art. 2). Bonds are delivered at their technical value at the applicable exchange rate. Total use is capped at US$ 3,500 million: up to US$ 1,000 million from 30 April 2025 to 29 April 2026; up to US$ 1,000 million from 30 April 2026 to 29 April 2027; up to US$ 1,500 million from 30 April 2027 to 31 October 2027. Art. 2 refers to "obligaciones tributarias y aduaneras vencidas" (overdue obligations), while RG ARCA 5675 art. 9 regulates application to advance payments; see Practical traps.
  • Protection and limits (arts. 3 to 5). The right to pay taxes with the bonds is declared an acquired right of subscriber and any holder, unaffected by any restructuring (art. 3). It ends once the BCRA pays the principal (pro rata if paid partially) (art. 4). Once delivered, the holder has no claim against the BCRA (art. 5).
  • Which strips (RG AFIP 5469/2023, BO 26 December 2023, art. 1). Only Series 1A, 1B and 1C have this tax paying power, each in its own window: 1A up to US$ 1,000 million from 30 April 2025 to 29 April 2026; 1B up to US$ 1,000 million from 30 April 2026 to 29 April 2027; 1C up to US$ 1,500 million from 30 April 2027 to 31 October 2027. Strip 1D and Series 2, 3 and 4 have no tax paying power. On 26 October 2026 the 1B window is open and the 1A window has closed.
  • Exchange rate (RG 5469 art. 2). The higher of (a) the average Com. A 3500 rate of the 5 business days before the reference date and (b) the average implicit rate of buying eligible government bonds with foreign currency settled locally and selling them for pesos (the local "MEP" implied rate) over the same 5 days, using the three most traded bonds on BYMA. RG ARCA 5675 art. 3(b)(1) sets the calculation method (spot settlement, price time priority segment only, volume weighted).
  • Procedure (RG ARCA 5675/2025, BO 16 April 2025, in force the next business day). The holder transfers the strips through a Caja de Valores participant to the ARCA custody account set in art. 2 (account 338958191 at Banco de la Nación Argentina, branch 0085, depositor 1128). Transfers are irrevocable and cannot be made on dates when the BCRA pays interest or amortisation (art. 2, last sentence added by RG 5714/2025, BO 18 June 2025). Caja de Valores reports the transfer to ARCA on form F.1400 the business day after credit, with the CUIT, the peso value and the certificate data (prefix 850 for 1A, 851 for 1B, 852 for 1C) (art. 3). ARCA publishes the daily BOPREAL value in its "Formas de pago" microsite (art. 3). ARCA records the amount as an electronic bond ("Bono Electrónico") in the web service "Administración de Incentivos y Créditos Fiscales", non transferable and non negotiable (art. 5). The taxpayer applies it with Clave Fiscal level 3, choosing the obligation (art. 6 and 7); for customs, application is to the customs broker profile CUIT (tax 2111, concept 800, subconcept 800) and appears in the customs system as payment means "IV" (art. 7). Application may start the business day after the transfer "en los plazos que... se indican a continuación" (art. 8); the table that follows in the official text is not reproduced in the Infoleg version we hold (unconfirmed). Applications never create freely available credits or refunds (arts. 7 and 9). Excess applied to advance payments can be moved to later obligations by a note filed through "Presentaciones Digitales" under the procedure "Bonos fiscales" (use of excess applied to advance payments, "Utilización de imputación en exceso de anticipos") (art. 9).

9. Impuesto PAIS

Decree 72/2023 art. 8 added art. 13 quáter to Decree 99/2019: the peso subscription of BCRA dollar bonds by import debtors was subject to the PAIS tax, at 0% until 31 January 2024 inclusive and, from 1 February 2024, at the rate that applied to the underlying imports, collected by the bank that debited the subscription. The PAIS tax ended on 22 December 2024 (RG ARCA 5765/2025, recitals). Importers that had paid PAIS advance payments at customs for goods registered up to 12 December 2023 and then subscribed BOPREAL at 0% could not use those advances; ARCA set a refund procedure (RG 5720/2025, BO 7 July 2025) and reopened it for filings from 6 October to 19 November 2025, with the first instalment available on 15 December 2025 (RG 5765/2025, BO 26 September 2025, arts. 1 to 4). The reopening window has closed (unconfirmed).

10. Banks as dividend payers

Financial entities that distribute profits under the BCRA rules on distribution of results must offer each non resident shareholder the option to receive its dividend in one cash instalment applied directly to a primary BOPREAL subscription. Those bonds cannot be moved to foreign depositaries or sold for foreign currency for 30 days (two thirds of face value) and 60 days (one third) from subscription, though they may be used freely otherwise, including as collateral (Com. A 7997 of 30 April 2024; Com. A 8235 of 30 April 2025, point 7.4 of the distribution of results text). The bank's own FX position from the subscription is excluded from its net global FX position (Com. A 8235; point 4.3 of that text, Com. A 8276). This page does not cover bank dividends further.

11. Tax treatment of the bonds

The sources contain no rule written specifically for BOPREAL in income tax or personal assets tax. The general rules point as follows, with the open points flagged.

  • Companies holding BOPREAL (third category income). Interest, gains on sale and the peso value changes of a dollar asset form part of the company's taxable income under the general rules, taxed at the corporate scale (ITL art. 73). For fiscal years starting in 2026 the scale is 25% up to ARS 133,514,185.74 (US$ 85,373), 30% up to ARS 1,335,141,857.38 (US$ 853,726) and 35% above, with the fixed amounts in the ARCA table (escala 2026). Timing of recognition of exchange differences and valuation at year end follow the general rules for foreign currency assets (unconfirmed).
  • Non residents. ITL art. 26(u) exempts non residents (not resident in, nor investing funds from, non cooperative jurisdictions) on interest and gains from "títulos públicos", defined as bonds and obligations issued by the National, provincial and municipal States and the City of Buenos Aires; the same paragraph expressly excludes BCRA LEBAC letters. Whether BOPREAL, issued by the BCRA and not by the National State, fall within the exemption is not resolved in the sources and is arguable both ways (unconfirmed). A non resident that receives BOPREAL as a dividend in kind, or buys them, should take advice before assuming exemption.
  • Resident individuals. Gains on securities in foreign currency are taxed at 15% (ITL art. 98(b)) unless an exemption applies; whether BOPREAL interest and gains are exempt for individuals depends on the same "títulos públicos" question (unconfirmed).
  • Personal assets tax. Law 23.966 art. 21(g) exempts securities "emitidos por la Nación, las provincias, las municipalidades y la Ciudad Autónoma de Buenos Aires". Whether BCRA notes count as issued by "la Nación" is not settled in the sources (unconfirmed). Companies are not personal assets taxpayers on their own holdings; they pay the tax on their shareholders' equity as substitute taxpayers (see Dividends and profits).
  • Dividend in kind. If a company delivers BOPREAL to its shareholders as a dividend, ITL arts. 49 and 75 (market value; gain at company level) and Law 19.550 art. 66(4) (directors' report must explain a non cash dividend) apply, as explained in Dividends and profits, Example 2.

12. How BOPREAL fits with the 2025 and 2026 dividend rules

  • Before April 2025. All dividends to non residents needed BCRA prior approval unless they fitted a narrow route (for example 30% of new FDI converted since 17 January 2020, point 3.4.4.4). BOPREAL (Series 3 in May 2024) was the only general exit offered by the BCRA.
  • From 14 April 2025. Point 3.4.4.1 (Com. A 8226, point 6) allows payment, without prior approval, of distributable profits from realised gains in regular audited annual statements of fiscal years started on or after 1 January 2025. For a calendar year company, the first such statements are those for 2025, approved in 2026.
  • Legacy profits. Profits of fiscal years started before 1 January 2025 still need prior approval or another route in 3.4.4. The BCRA's Series 4 (30 April 2025 framework; auctions 18 June, 2 July and 16 July 2025) was explicitly opened to dividend debtors under 4.6 alongside the April 2025 easing, and was then closed with the "última licitación" of 16 July 2025 (Com. B 13014).
  • In 2026. The consolidated text at 14 September 2026 keeps 3.4.4.1 with the 1 January 2025 cut off and keeps BOPREAL subscription for dividends that are subject to prior approval (point 3.4, last paragraph). Our probe of Com. A 8482 to A 8497 (to 22 October 2026) and the communications incorporated in the text up to A 8481 found no further easing for legacy dividends (unconfirmed). So, today: new profits flow; legacy profits need prior approval, the peso dividend and CCL route (with its 90 day cost), or BOPREAL dollars from an earlier subscription.

Step by step

A. If the BCRA calls a new auction (none is open today).

  1. Check that the debt fits. Goods with customs entry up to 12 December 2023 (4.4), services provided up to that date (4.5), dividends pending that need prior approval (4.6.1 and 3.4), peso dividends collected since 1 September 2019 (4.6.2) or overdue related party debts (4.7). Confirm in the auction notice who may subscribe; Series 2 was for SMEs only and Series 4 for legal entities only.
  2. Bring the survey up to date. The debt must appear in the last "Relevamiento de activos y pasivos externos" already due. From the 2026 data, the main sample (US$ 10 million or more) files quarterly within 45 days and the rest annually within 90 days (Com. A 8304).
  3. Prepare the documents. Goods: SEPAIMPO certificate of the unpaid amount from the bank that follows the customs entry. Services: contracts, invoices and evidence of provision. Dividends: audited statements, meeting minutes with the allocation to non residents. Related party debt: loan or supply contracts and the amount due.
  4. Sign the sworn statements. Points 3.16.1 to 3.16.4 (90 day and group statements) and the specific statement of 4.4.5, 4.5.4, 4.6.1.4, 4.6.2.3 or 4.7.4, signed by the legal representative or an attorney with sufficient powers. Read the FX waiver before signing.
  5. Place the bid through your bank. The bank enters the bid on the SIOPEL "BPAL" wheel of MAE during the auction hours (11:00 to 15:00 in every call found), stating the face value in US$ and the CUIT or CUIL (Com. B 12695, B 12999). Allotment is pro rata if demand exceeds the cap.
  6. Fund in pesos. The bank debits the pesos at the Com. A 3500 rate of the business day before the auction and books the sale ticket with the right concept code. Settlement has been some days after the auction (for example offers on 16 July 2025, settlement on 21 July 2025).
  7. Hold the bonds in a custody account that allows coupon collection in dollars into a local dollar account, since those dollars are the key to later FX access (4.8.1).

B. Paying the creditor with BOPREAL dollars.

  1. Collect coupon or principal in a local foreign currency account.
  2. Ask the bank to carry out the swap or arbitrage and transfer abroad citing point 4.8.1 (or 3.4.4.2, 3.5.6.5, 10.11.4 as relevant), with evidence that the funds come from BOPREAL collections and that the debt was the eligible one.
  3. Keep the trail: custody statements showing the collection, the original subscription ticket (B26, S33, I09, P21, I12, I13 or P28).

C. Selling the bonds.

  1. Decide the channel: sale for dollars in Argentina ("MEP" settlement), sale against cable to the company's own foreign account, or sale against cable to a third party abroad (only for primary subscribers under 4.4, 4.5, 4.6.1 and 4.7; points 4.3.2.3 and 4.8.3).
  2. Check the face value against the amount acquired in the primary subscription; sales above it lose the 90 day relief (point 3.16.3.6.iv).
  3. If the sale is below par and you are an importer under 4.4 or 4.5, compute the "difference" allowance for other securities (point 4.8.2, second paragraph).
  4. Record the sale for income tax.

D. Paying taxes with 1B (open window) or 1C (from 30 April 2027).

  1. Check that the window is open and that the system wide cap has room (unconfirmed).
  2. Avoid BCRA payment dates (30 April and 31 October for Series 1) for the transfer.
  3. Instruct your Caja de Valores participant to transfer the strips to the ARCA account in RG 5675 art. 2. The transfer is irrevocable.
  4. From the business day after transfer, log in with Clave Fiscal level 3 to "Administración de Incentivos y Créditos Fiscales", find the electronic bond and apply it to the obligation (capital and/or interest). For customs obligations apply it to the customs broker profile.
  5. Keep the constancy the system issues.

E. Exercising the put (1A, 1B now; 1C from 30 April 2027; 4A from 30 April 2028).

  1. Deposit the strips in CRyL by the business day before.
  2. Instruct the bank to exercise on the SIOPEL wheel set up for that purpose.
  3. Receive pesos at the Com. A 3500 rate of the exercise day, on T+2 (Series 1) or T+1 (Series 4).

Cost to do it. No BCRA fee, tax authority fee or stamp is set in the sources for subscribing, holding, exercising or delivering BOPREAL. Bank, broker and custody fees are agreed with each entity and are not in the sources (unconfirmed). Capital: subscription requires pesos equal to face value × Com. A 3500 rate (for US$ 1,000,000, ARS 1,563,900,000, about US$ 1,000,000 at the MEP rate of some secondary summaries, if the A 3500 rate equalled MEP; in practice it differs (unconfirmed)). Time: auctions were held weekly or fortnightly while open; settlement took about one week; tax credit application from the business day after transfer; put proceeds T+1 or T+2. Total time to get dollars depends on the series schedule (up to 31 October 2027 for Series 1 and 31 October 2028 for Series 4) unless you sell at a discount.

Costs and timelines

Series terms at a glance

Item Series 1 (BPO27) Series 2 (BPJ25) Series 3 (BPY26) Series 4 (BPO28)
Framework Com. A 7918 Com. A 7918 Com. A 7918 Com. A 8233
Detailed terms Com. B 12695, B 12697 Com. B 12695, B 12736 Com. B 12695, B 12750 Com. B 12999
Issue date 5 Jan 2024 16 Feb 2024 7 Mar 2024 24 Jun 2025
Maturity 31 Oct 2027 30 Jun 2025 31 May 2026 31 Oct 2028
Status on 26 Oct 2026 Outstanding Matured Matured Outstanding
Coupon 5% a year, half yearly None 3% a year, quarterly 3% a year, half yearly
Day count 30/360 n/a 30/360 30/360
Amortisation 50% 30 Apr 2027, 50% 31 Oct 2027 12 monthly, Jul 2024 to Jun 2025 33% 30 Nov 2025, 33% 28 Feb 2026, 34% 31 May 2026 100% at maturity
Strips and holder put 1A 20% (from 30 Apr 2025), 1B 20% (from 30 Apr 2026), 1C 30% (from 30 Apr 2027), 1D 30% (none) None None 4A 1/3 (from 30 Apr 2028), 4B 2/3 (none)
Put settlement T+2, pesos at A 3500 of exercise day n/a n/a T+1, pesos at A 3500 of exercise day
BCRA early call On interest dates, in dollars On amortisation dates, in dollars On interest dates, in dollars None stated
Who could subscribe Importers (4.4, 4.5) SMEs in the Padrón, one bid per CUIT Padrón importers; from May 2024 also 4.6 dividend subscribers Legal entities under 4.4, 4.5, 4.6 and 4.7 debtors
Maximum issue US$ 750 million (calls of 22 Dec 2023 to 15 Jan 2024), US$ 5,000 million (calls of 19 and 26 Jan 2024) VN US$ 2,000 million VN US$ 3,000 million US$ 3,000 million
Pays federal taxes 1A, 1B, 1C only No No No
Listed BYMA/MAE, Caja de Valores, Euroclear BYMA/MAE per Feb 2024 calls BYMA/MAE BYMA/MAE

Amounts actually awarded in each auction are not in the sources (unconfirmed). The successive Series 3 calls lowered the cap from VN US$ 3,000 million (Com. B 12750) to VN US$ 60,300,630 (Com. B 12810), which suggests most of the series was placed by May 2024, but the BCRA did not state this (unconfirmed).

Coupon arithmetic per US$ 1,000,000 of face value

Series Coupon per full period Periods per year Annual interest
Series 1 US$ 25,000 (5% × 180/360) 2 US$ 50,000
Series 3 US$ 7,500 (3% × 90/360) 4 US$ 30,000
Series 4 US$ 15,000 (3% × 180/360) 2 US$ 30,000

Peso equivalents at MEP ARS 1,563.90 (unconfirmed): US$ 25,000 = ARS 39,097,500; US$ 15,000 = ARS 23,458,500; US$ 50,000 = ARS 78,195,000; US$ 30,000 = ARS 46,917,000.

Eligibility and concept codes

FX point Debt Cut off Code Origin
4.4 Imports of goods Customs entry up to 12 Dec 2023 B26 Com. A 7925, point 1
4.5 Imports of services Provided or accrued up to 12 Dec 2023 S33 Com. A 7925, point 2
4.6.1 Dividends pending to non residents Audited balance sheets; must need prior approval I09 Com. A 7999, point 1
4.6.2 Peso dividends collected by non residents Collected from 1 Sep 2019, CPI adjusted P21 Com. A 7999, point 2
4.7.i Related party commercial interest Due up to 4 Jul 2024 I12 Com. A 8234
4.7.ii Related party financial interest Due up to 31 Dec 2024 I13 Com. A 8234
4.7.iii Related party financial principal Overdue P28 Com. A 8234

Tax payment windows (Series 1 strips)

Strip ARCA certificate prefix Window Cap (all holders together) Status on 26 Oct 2026
1A 850 30 Apr 2025 to 29 Apr 2026 US$ 1,000 million Closed
1B 851 30 Apr 2026 to 29 Apr 2027 US$ 1,000 million Open
1C 852 30 Apr 2027 to 31 Oct 2027 US$ 1,500 million Not yet open

Sources: Decree 72/2023 art. 2; RG 5469 art. 1; RG 5675 art. 3(c).

Thresholds and percentages

Item Figure Source
Series 1 subscription for the special window At least 50% of eligible debts, before 31 Jan 2024 Point 4.8.4
Payment allowed under 4.8.4.1 Up to 5% of Series 1 subscribed Point 4.8.4.1
Monthly cap under 4.8.4.2 10% of eligible debts without BOPREAL Point 4.8.4.2
Monthly cap under 4.8.4.3 and 4.8.5 10% of export advances used Points 4.8.4.3, 4.8.5
Reduced window At least 25% subscribed; up to 50% of export advances settled Point 4.8.5
Series 2 priority allocation First VN US$ 500,000 per CUIT Com. B 12736
Bank dividend lock up 2/3 for 30 days, 1/3 for 60 days Com. A 7997, A 8235
Tax payment cap US$ 3,500 million in total Decree 72/2023 art. 2
Liquid foreign assets statement US$ 100,000 Point 3.16.2 (see Exchange controls)

Deadlines and dates

Event Date Source
Debt cut off for importers 12 Dec 2023 (inclusive) Points 4.4, 4.5
PAIS rate 0% on subscriptions Until 31 Jan 2024 Decree 72/2023 art. 8
Series 1 special window subscriptions Before 31 Jan 2024 Points 4.8.4, 4.8.5
Last bonds eligible for tax payment issued 31 Mar 2024 Decree 72/2023 art. 1
Series 1 strip 1 Mar 2024 Com. B 12695
Cable to third party for other securities (importers' difference) From 1 Apr 2024 Point 4.8.3
Series 4 strip 30 Sep 2025 Com. B 12999
Last Series 4 auction 16 Jul 2025 (settled 21 Jul 2025) Com. B 13014
Next Series 1 coupon 31 Oct 2026 Com. B 12695
Next Series 4 coupon 31 Oct 2026 Com. B 12999
Series 1 amortisations 30 Apr 2027 and 31 Oct 2027 Com. B 12695
Series 4 put opens (4A) 30 Apr 2028 Com. B 12999
Series 4 maturity 31 Oct 2028 Com. B 12999
Survey filing (secondary sample, from 2026 data) 90 calendar days after year end Com. A 8304
Survey filing (main sample, quarterly) 45 calendar days after quarter end Com. A 8304

Timeline of norms

BCRA communications are not published in the Boletín Oficial; the date shown is the date of the communication.

Date Norm Content
13 Dec 2023 Com. A 7918 BOPREAL created (framework)
21 Dec 2023 (BO 22 Dec 2023) Decree 72/2023 Tax payment with BCRA bonds; PAIS art. 13 quáter
22 Dec 2023 Com. A 7925 FX rules for importers (later points 4.4, 4.5, 4.8)
22 Dec 2023 Com. B 12695 Terms of Series 1, 2 and 3
22 Dec 2023 Com. B 12697 First Series 1 auction (27 and 28 Dec 2023)
22 Dec 2023 (BO 26 Dec 2023) RG AFIP 5469 Strips 1A, 1B, 1C may pay taxes; exchange rate
28 Dec 2023 Com. A 7935 and Com. C 96983 Series 1 window deadline to 31 Jan 2024; 90 day relief for other securities
11 Jan 2024 Com. A 7940, A 7941 Cable to third parties; Series 1 windows rewritten
19 and 26 Jan 2024 Com. B 12727, B 12730 Series 1 cap US$ 5,000 million; reminder that extra benefits end 31 Jan 2024
25 Jan 2024 Com. A 7952 Other securities against cable to third parties from 1 Apr 2024
5 Feb 2024 Com. B 12736 First Series 2 auction (SMEs)
26 Feb 2024 Com. B 12750 First Series 3 auction
30 Apr 2024 Com. A 7999 BOPREAL for dividends (4.6.1, 4.6.2)
30 Apr 2024 Com. A 7997 Banks' non resident shareholders may take BOPREAL
3 May 2024 Com. B 12795 Series 3 opened to dividend subscribers
20 May 2024 Com. B 12810 Last Series 3 auction call found
28 Jun 2024 Com. A 8055 Repo treatment
11 Apr 2025 (effective 14 Apr 2025) Com. A 8226, point 6 Free access for dividends from fiscal years started from 1 Jan 2025
14 Apr 2025 (BO 16 Apr 2025) RG ARCA 5675 Procedure to pay taxes with BOPREAL
30 Apr 2025 Com. A 8233, A 8234, A 8235 Series 4; related party debts (4.7); banks' dividends
10 Jun 2025 Com. B 12999 Series 4 terms; first auction 18 Jun 2025
BO 18 Jun 2025 RG ARCA 5714 No transfers to ARCA on BCRA payment dates
BO 7 Jul 2025 RG ARCA 5720 PAIS advance payment refunds
14 Jul 2025 Com. B 13014 Last Series 4 auction (16 Jul 2025)
19 Aug 2025 Com. A 8304 Survey thresholds and deadlines from 2026 data
BO 26 Sep 2025 RG ARCA 5765 PAIS refund register reopened (6 Oct to 19 Nov 2025)
14 Sep 2026 Com. A 8481 FX consolidated text updated (Section 4 unchanged in substance)

Worked examples

All market prices and official rates below are assumptions for illustration; none comes from a source unless cited. Rerun the numbers with real quotes on the day.

Example 1. Subsidiary with US$ 2,000,000 of pending dividends: BOPREAL Series 4 or wait

Facts. Filial SA, a calendar year company, is 100% owned by a foreign parent. Its retained earnings come from fiscal years 2022 to 2024 (all started before 1 January 2025). In 2025 the shareholders' meeting allocated a dividend whose net amount pending to the parent, after the dividend withholding already deposited (see Dividends and profits), is ARS 3,127,800,000. The audited statements, minutes and survey filing are in order. The company considers the last Series 4 auction of 16 July 2025.

Assumption: Com. A 3500 rate on the business day before the auction = ARS 1,563.90 per US$ (chosen to equal the 23 Oct 2026 dólar MEP rate for simplicity; the actual July 2025 rate is not in the sources (unconfirmed)).

Step 1. Is FX access available without BOPREAL? Point 3.4.4.1 covers only profits of fiscal years started on or after 1 January 2025, so it does not cover these dividends. Filial SA has no FDI contributions since 17 January 2020 (3.4.4.4) and no Decree 277/22 or export certificates. The only official routes are BCRA prior approval (3.4, closing paragraph) or BOPREAL (3.4, last paragraph; 4.6.1). The FX rules give no deadline or criteria for prior approval (unconfirmed).

Step 2. Route A: subscribe Series 4.

  1. Face value: ARS 3,127,800,000 ÷ 1,563.90 = VN US$ 2,000,000 of BPO28, booked under code I09.
  2. Sworn statement 4.6.1.4: Filial SA gives up FX access for this dividend except through BOPREAL collections.
  3. Strip on 30 September 2025: VN US$ 666,666.67 of 4A and VN US$ 1,333,333.33 of 4B (1/3 and 2/3; Com. B 12999).
  4. Coupons. First coupon on 31 October 2025, counted from the issue date of 24 June 2025 on 30/360: 126 days, so US$ 2,000,000 × 3% × 126/360 = US$ 21,000. Whether a subscriber at the later auction of 16 July 2025 paid accrued interest from 24 June at settlement is not stated in the notice, which only says "a la par" (unconfirmed). Each later coupon: US$ 2,000,000 × 3% × 180/360 = US$ 30,000, six times (30 April 2026 to 31 October 2028) = US$ 180,000.
  5. Cash to the parent if held to maturity: US$ 21,000 + US$ 180,000 + US$ 2,000,000 = US$ 2,201,000 (ARS 3,442,143,900 at MEP), paid in instalments through 31 October 2028 by swapping each collection under 4.8.1.3 and 3.4.4.2.
  6. Status on 26 October 2026: coupons of 31 October 2025 and 30 April 2026 collected, US$ 51,000 (ARS 79,758,900) already remitted; the 31 October 2026 coupon of US$ 30,000 (ARS 46,917,000) is due in five days.
  7. Effective rate if held to maturity: ARS 3,127,800,000 ÷ US$ 2,201,000 = ARS 1,421.08 per US$ received, ignoring the time value of money and BCRA credit risk.
  8. Faster alternative: sell the bonds against cable directly to the parent's account abroad (4.3.2.3 and 4.8.3); see Example 2 for the effective rate.

Step 3. Route B: wait.

  1. Filial SA keeps ARS 3,127,800,000 as a liability to its parent. Waiting does not make these profits eligible under 3.4.4.1, because eligibility depends on the fiscal year in which the profits were earned, not on the date of payment. Waiting only helps if the BCRA changes the rule, grants prior approval, or the company finds another route.
  2. Meanwhile, new profits change the picture. If Filial SA's 2025 audited statements show distributable profits, those can be paid from 2026 under 3.4.4.1. Whether a company may choose to distribute 2025 profits first while older retained earnings remain undistributed, and how the bank checks the origin of each peso, is not specified in the FX text (unconfirmed).
  3. The dollar value of the trapped pesos depends on the peso yield the company earns and the exchange rate when payment is finally allowed. Formula: US$ value at payment = (ARS 3,127,800,000 + peso return) ÷ exchange rate at payment. No source gives either variable.
  4. A further alternative is a peso dividend paid locally, with the parent converting through CCL; it is lawful for the shareholder within securities rules but freezes the company's own FX access for 90 days through the group statement (point 3.16.3.4); see Dividends and profits, Example 2.

Step 4. Comparison.

Route US$ to parent When Risks
A1 Series 4 held to maturity 2,201,000 Coupons to Oct 2028, principal 31 Oct 2028 BCRA credit; three year wait for principal
A2 Series 4 sold at once (Example 2) 1,791,000 at an assumed 90% and 0.5% fee Days Market price
B Wait Unknown Unknown Rule may not change; peso depreciation; prior approval uncertain

Today (October 2026). The choice in this example is historical: no auction is open, so a company in Filial SA's position today cannot subscribe. It can only seek prior approval, use routes in 3.4.4, or pay in pesos locally. A company that subscribed in 2025 now faces the hold or sell decision in Example 2.

Example 2. Selling BOPREAL in the secondary market: the effective exchange rate

Part (a). Filial SA sells its Series 4 against cable to the parent.

Assumptions: on 26 October 2026, BPO28 (4A and 4B together) can be sold abroad at an all in price of 90.00% of face value including accrued interest; broker and custody cost 0.5% of proceeds (unconfirmed).

  1. Gross proceeds: US$ 2,000,000 × 90.00% = US$ 1,800,000 (ARS 2,815,020,000).
  2. Cost: US$ 1,800,000 × 0.5% = US$ 9,000 (ARS 14,075,100).
  3. Net to the parent: US$ 1,791,000 (ARS 2,800,944,900), credited directly to the parent's foreign account (points 4.3.2.3 and 4.8.3; account not in a FATF non compliant jurisdiction).
  4. FX treatment: the sale is up to the amount acquired in the primary subscription, so it is ignored for Filial SA's 90 day statements (3.16.3.6.iv; 4.8.2). Filial SA can keep using the official market for imports and debt in the same window.
  5. Effective exchange rate of the sale alone: ARS 3,127,800,000 ÷ US$ 1,791,000 = ARS 1,746.40 per US$, about 11.7% above the A 3500 rate assumed at subscription (1,563.90).
  6. Including the two coupons already remitted (US$ 51,000): ARS 3,127,800,000 ÷ US$ 1,842,000 = ARS 1,698.05 per US$.
  7. Shortfall: US$ 2,000,000 minus US$ 1,791,000 leaves US$ 209,000 (ARS 326,855,100) of the original dividend is not covered. Filial SA signed that it would not buy dollars for this dividend except through BOPREAL collections (4.6.1.4.iii); having sold the bonds, it has no collections left, so the shortfall cannot be paid through the official market. Unlike importers, dividend subscribers do not get the "difference" allowance for other securities (4.8.2, second paragraph, covers only 4.4 and 4.5). The parent and the company must agree whether the dividend is fully discharged by the delivery of US$ 1,791,000 plus the coupons, or a peso balance remains.
  8. Income tax: Filial SA recognises the result on sale (proceeds in pesos at the sale date rate minus tax cost) under the general rules (ITL art. 73) (unconfirmed).

Part (b). A Series 1 holder compares the 1B put with a sale.

Facts and assumptions: an importer holds VN US$ 200,000 of 1B from its January 2024 subscription. On the exercise day the Com. A 3500 rate is assumed at ARS 1,500.00 and 1B can be sold for dollars locally at 97.00% with a 0.5% cost; the MEP rate is ARS 1,563.90 (unconfirmed).

  1. Put: 200,000 × ARS 1,500.00 = ARS 300,000,000, paid T+2. If the company then wanted dollars at the MEP rate: 300,000,000 ÷ 1,563.90 = US$ 191,828.12. But buying MEP dollars means buying bonds for pesos and selling them for dollars; that sale is not a BOPREAL sale, so it falls within the 90 day cross restriction (3.16.3.1.i and 3.16.3.2.i) and would block the company's official market access for 90 days.
  2. Sale for dollars: 200,000 × 97.00% = US$ 194,000, less 0.5% = US$ 193,030 (ARS 301,879,617). This sale is up to the primary amount and is ignored for the 90 day statements (3.16.3.6.iv).
  3. Break even: the sale is better than the put converted at MEP whenever the dollar price exceeds A 3500 ÷ MEP = 1,500.00 ÷ 1,563.90 = 95.91% (before costs). With these assumptions the sale wins by US$ 1,201.88, and also preserves FX access.
  4. Effective rate of the put in pesos: the holder exchanged a US$ 200,000 claim for ARS 300,000,000, i.e. ARS 1,500.00 per US$ of face value, the official rate. If the importer's objective is to pay pesos expenses, the put gives a guaranteed peso floor; if it needs dollars, the market sale is usually more efficient.

Example 3. Paying federal taxes with strip 1B

Facts and assumptions: a company holds VN US$ 100,000 of 1B in November 2026, just after the 31 October 2026 coupon, so technical value is assumed at 100% of face value. The 5 day average Com. A 3500 rate is assumed at ARS 1,500.00 and the 5 day average implied local rate at ARS 1,590.00 (unconfirmed).

  1. Rate used by ARCA: the higher of the two (RG 5469 art. 2) = ARS 1,590.00.
  2. Tax credit: 100,000 × 100% × ARS 1,590.00 = ARS 159,000,000 (US$ 101,668.90 at MEP).
  3. Compare a peso sale at the MEP equivalent of 97%: 100,000 × 0.97 × 1,563.90 = ARS 151,698,300 (US$ 97,000). Compare the put: 100,000 × 1,500.00 = ARS 150,000,000 (US$ 95,914.06).
  4. With these assumptions the tax route yields ARS 7,301,700 more than the sale and ARS 9,000,000 more than the put, if the company has enough eligible federal taxes (not payroll contributions, not the bank tax, not amounts withheld from third parties) and the 1B cap has room.
  5. Excess applied to advance payments is not refunded; it can only be moved to future obligations within the window (RG 5675 art. 9).

Practical traps

  1. No primary market today. The BCRA called the 16 July 2025 auction the last one for Series 4 and no later call appears up to 16 October 2026. Do not plan a dividend or import payment on the basis of a future BOPREAL auction unless one is announced.
  2. The waiver is permanent for that debt. After subscribing under 4.6.1 or 4.7, the debt can only be paid with BOPREAL dollars. If you sell below par, the gap cannot be bought in the official market (Example 2(a)).
  3. Dividend route only for dividends that need prior approval. Point 3.4, last paragraph, limits 4.6.1 to dividends subject to prior approval. Profits from fiscal years started from 1 January 2025 already have free access.
  4. The 90 day relief is capped at the primary amount and only for primary subscribers. A company that bought additional BOPREAL in the market and sells them for dollars triggers the cross restriction like any other bond sale (3.16.3.6.iv).
  5. Putting 1A or 1B and buying MEP dollars is not the same as selling BOPREAL for dollars. The MEP purchase involves a sale of other securities for dollars, which is within the cross restriction.
  6. Only 1A, 1B and 1C pay taxes, in their own windows, with a system wide cap. 1D and Series 2, 3 and 4 do not. The cap is shared by all holders; once used, later deliveries may be rejected (unconfirmed).
  7. Taxes you cannot pay with BOPREAL. Social security, health insurance, life insurance, ART premiums, the bank debit and credit tax, and amounts you owe as withholding or collection agent (Decree 72/2023 art. 1).
  8. "Vencidas" versus advance payments. Decree 72/2023 art. 2 speaks of overdue tax obligations, while RG 5675 art. 9 regulates application to advance payments. Check with ARCA before applying bonds to current period advances (unconfirmed).
  9. Transfer dates. Transfers to ARCA are irrevocable and not allowed on BCRA payment dates (RG 5675 art. 2 as amended by RG 5714/2025).
  10. Put exercise logistics. Bonds must be in CRyL the day before; settlement is T+2 for Series 1 and T+1 for Series 4; the rate is that of the exercise day. A7918 also mentions 5 business days' notice; check with your bank.
  11. Survey filings. Every eligibility test requires the debt to be in the last survey due. The 2026 survey rules changed thresholds and deadlines (Com. A 8304).
  12. Non resident tax exemption is uncertain. ITL art. 26(u) speaks of bonds issued by the National State and expressly excludes LEBAC; BOPREAL are BCRA notes. Do not assume the exemption.
  13. Series 2 listing. Com. B 12695 said Series 2 would not be listed, while the February 2024 calls said it would. It matured on 30 June 2025, so this now matters only for historic tax filings.
  14. Accrued interest at later auctions. All auctions were "a la par" with an issue date earlier than settlement for later calls (for example Series 4 issued 24 June 2025 and settled 21 July 2025). How accrued interest was handled is not in the notices (unconfirmed).

Recent changes

  • 30 April 2025 (Com. A 8233, A 8234, A 8235). Series 4 framework; BOPREAL for overdue related party debts (new point 4.7); banks' dividends into BOPREAL renewed.
  • 14 April 2025 (Com. A 8226, point 6). Free FX access for dividends from fiscal years started from 1 January 2025, reducing the need for BOPREAL for new profits.
  • 16 April 2025 (RG ARCA 5675). Procedure to pay taxes with 1A, 1B and 1C, starting with the 1A window from 30 April 2025.
  • 18 June 2025 (RG ARCA 5714). Transfers to ARCA barred on BCRA payment dates.
  • June to July 2025 (Com. B 12999, B 13011, B 13014). Series 4 auctions on 18 June, 2 July and 16 July 2025; the last one described as final.
  • 30 June 2025. Series 2 final instalment (Com. B 12736 terms).
  • 26 September 2025 (RG ARCA 5765). PAIS refund register reopened for imports for which BOPREAL was subscribed at 0%; filings 6 October to 19 November 2025.
  • 30 September 2025. Series 4 split into 4A and 4B.
  • 29 April 2026. Tax payment window for 1A closed; 1B window opened 30 April 2026.
  • 31 May 2026. Series 3 final instalment.
  • 14 September 2026 (Com. A 8481). FX consolidated text updated; Section 4 BOPREAL rules unchanged in substance.

Pending changes

  • New auctions. Whether the BCRA will offer another series for remaining legacy dividends or related party debts (unconfirmed).
  • Legacy dividends. No 2026 BCRA rule found that frees profits of fiscal years started before 1 January 2025 (unconfirmed).
  • Point 3.4.4.2 scope. Whether secondary market BOPREAL collections can be used to pay dividends not subscribed under 4.6.1 (unconfirmed).
  • Tax treatment for non residents and individuals. Whether BOPREAL are "títulos públicos" for ITL art. 26(u) and art. 21(g) of the personal assets law (unconfirmed).
  • RG 5675 art. 8 timetable. Not reproduced in the Infoleg text held (unconfirmed).
  • Upcoming events. Series 1 coupon 31 October 2026; 1C tax window and put from 30 April 2027; Series 1 amortisations 30 April and 31 October 2027; 4A put from 30 April 2028; Series 4 maturity 31 October 2028.

FAQ

1. Can I still subscribe BOPREAL? Not today. The last auction was on 16 July 2025 (Com. B 13014) and no later call appears up to 16 October 2026. The FX rules still describe subscription, so a new auction would only need a BCRA call (unconfirmed).

2. Which series are still outstanding? Series 1 (maturing 31 October 2027, as strips 1A to 1D) and Series 4 (maturing 31 October 2028, as strips 4A and 4B). Series 2 matured on 30 June 2025 and Series 3 on 31 May 2026.

3. What interest do they pay? Series 1 pays 5% a year in two half yearly coupons; Series 4 pays 3% a year half yearly; both on 30/360 and in dollars. Series 3 paid 3% quarterly and Series 2 paid no interest (Com. B 12695, B 12999).

4. Can I use BOPREAL to pay taxes? Only strips 1A, 1B and 1C, each in its window and within a system wide cap. On 26 October 2026 the 1B window (30 April 2026 to 29 April 2027) is open. Payroll contributions, the bank tax and withholding agent obligations are excluded (Decree 72/2023; RG 5469; RG 5675).

5. My company subscribed BOPREAL for a 2023 dividend. Can it now pay the rest of the dividend in the official market because rules were eased in 2025? No. The 2025 easing covers profits of fiscal years started from 1 January 2025 (3.4.4.1). For the dividend subscribed, the company waived FX access except through BOPREAL collections (4.6.1.4.iii). For any part of the old dividend not subscribed, it still needs prior approval or another route in 3.4.4.

6. Can we sell the bonds and have the dollars paid straight to our parent? Yes, if you subscribed in the primary market under 4.4, 4.5, 4.6.1 or 4.7: you may sell against cable to a third party's account abroad that is not in a FATF non compliant jurisdiction (4.3.2.3; 4.8.3). The sale, up to the primary amount, is ignored for the 90 day statements (3.16.3.6.iv).

7. Does selling BOPREAL block our access to the official market for 90 days? Not if you are the primary subscriber and sell no more than the face value you subscribed (3.16.3.6.iv; 4.8.2). Bonds bought in the secondary market do not get this relief.

8. What is the put on 1A, 1B, 1C and 4A worth? It lets you redeem face value in pesos at the Com. A 3500 rate of the exercise day (T+2 for Series 1; T+1 for Series 4). It is a peso floor, not a dollar payment. Compare it with the dollar price: if the price is above A 3500 ÷ MEP, selling for dollars yields more (Example 2(b)).

9. Can the BCRA redeem early? For Series 1 (and Series 2 and 3) the BCRA reserved an option to redeem early on payment dates, paying dollars (Com. B 12695). The Series 4 notice does not include such an option (Com. B 12999).

10. How are BOPREAL taxed? For companies, interest and gains are part of taxable income at the corporate scale (ITL art. 73). For non residents and individuals, whether the "títulos públicos" exemptions apply to BCRA notes is not resolved in the sources, and the law expressly excludes BCRA LEBAC from the non resident exemption (unconfirmed).

11. We paid PAIS at customs and then used BOPREAL. Can we get the PAIS back? ARCA created a refund procedure (RG 5720/2025) and reopened it from 6 October to 19 November 2025 for, among others, goods registered up to 12 December 2023 for which BOPREAL was subscribed at 0% PAIS (RG 5765/2025). That window has closed (unconfirmed).

12. Can a bank shareholder abroad take dividends in BOPREAL? Yes; banks distributing profits must offer non resident shareholders a primary BOPREAL subscription with the dividend, subject to a 30 and 60 day lock up on moving or selling the bonds for dollars (Com. A 7997; Com. A 8235).

Published 27 Oct 2026 from our research draft. Points marked (unconfirmed) have not yet been checked line by line against the official text; rely on the primary sources linked below before acting, and expect this page to change as we verify it.

Primary sources

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