The Argentine Thread

Guide · 5. FX and capital controls

Paying for imports and foreign services under Argentina's FX rules

Last verified: 27 Oct 2026 · Status: Changing

An Argentine importer that owes money abroad for goods or services pays by buying foreign currency through its bank in the official FX market. The bank checks that the payment is genuine, correctly classified and within the timetable the BCRA allows (points 1.2, 10.3.2 and 13.1). Every exchange ticket (boleto) counts as the client's sworn statement (point 5.3), and every breach falls under the Criminal Exchange Regime Law 19.359 (point 1.5).

The rules are much looser in October 2026 than they were two years earlier. The main points:

  • Goods with customs entry. Since 14 April 2025, every import registered at customs can be paid from the date of customs entry, with no waiting period (point 10.10.1; Com. A 8226, point 7). Under the previous rules most goods had to wait 30 calendar days after customs entry (point 10.10.1.2 in the text circulated with Com. A 8191 of 10 February 2025).
  • Before customs entry. Paying before the goods are registered at customs still needs a specific permission. The main ones are sight payments and commercial debt payments by individuals and SMEs for goods shipped from 14 April 2025 (point 10.10.2.1). Another is capital goods, which may be paid up to 30% of FOB in advance and up to 80% of FOB counting advance, sight and unregistered debt payments (point 10.10.2.2). Payments funded by eligible financing are a third route (points 10.10.2.3 to 10.10.2.14). Anything else needs BCRA prior approval (points 10.4.2.8 and 10.4.3.7). Advance payments to a related supplier always need prior approval (point 10.4.2.4).
  • Services from unrelated providers can be paid from the date the service is provided or accrues (point 13.2.5).
  • Services from related providers, including royalties, licence fees and management fees charged by a foreign parent, can only be paid 90 calendar days after the service is provided or accrues (point 13.2.6). Before 14 April 2025 the wait was 180 days for related providers and 30 days for unrelated ones (points 13.2.6 and 13.2.7 in the Com. A 8191 text).
  • The SIRA, SIRASE and SEDI systems are gone. SEDI replaced SIRA from December 2023 (Joint RG 5466/2023, BO 26 December 2023). The repeal of Joint RG 5271/2022 took the SIRASE services regime with it (Joint RG 5466/2023, art. 15). SEDI itself was abolished from 26 February 2025, and all pending SEDI declarations lapsed (Joint RG 5651/2025, arts. 1 and 2, BO 25 February 2025).
  • The PAIS tax is gone. It applied to foreign currency purchases for imports, among other operations, from 23 December 2019 to 22 December 2024 inclusive (Law 27.541, art. 35; as recited in RG 5720/2025). It was not abolished by decree. It expired at the end of its five fiscal period term (Law 27.541, art. 35). Decree 777/2024 only reduced the rate for some import cases (RG 5720/2025, recitals).
  • Old debts. Import debts for goods registered, or services provided, up to 12 December 2023 still need BCRA prior approval unless an exception applies. The usual exits were BOPREAL bonds, the SME window for debts up to USD 500,000, and payments financed or guaranteed by banks or export credit agencies before 13 December 2023 (points 10.11 and 13.4).
  • The general checks still apply. These are the USD 100,000 liquid foreign assets statement and, for companies, the 90 day "cross restriction" on securities trades before and after access (points 3.16.2 and 3.16.3). These are covered in detail on the exchange controls page. Buying dollars through the MEP or CCL securities market in the 90 days before an import payment can block that payment (point 3.16.3.1). See MEP and CCL.

Cost to do it. No BCRA fee applies to an FX market import or service payment, and the FX rules set none. Bank FX commissions, SWIFT charges and the bank's spread are commercial terms not found in the sources (unconfirmed). Paying the supplier is quick once the documents are in order: SEPAIMPO payment certificates are valid for 10 business days (point 11.1.3). The real costs are the customs taxes, covered on the customs duties page, and, for services, the income tax withheld from the foreign provider and the reverse charge VAT (ITL arts. 102 to 104; VAT Law art. 1 d)). Related party services also carry a cash cost from the 90 day wait. Registering a technology or licence contract with INPI carries a fee (unconfirmed), and the INPI has 30 day observation windows (INPI Res. 38/2026, Annex, item M).

COMPARISON: to be sourced by editor

Who should read this page.

  • Local SMEs importing machinery, inputs or finished goods.
  • Argentine subsidiaries buying goods, software, royalties, management services or technical assistance from a foreign parent or sister company.
  • Foreign suppliers deciding whether to ask for advance payment, a letter of credit or open account terms.
  • Advisers planning payment schedules, intercompany agreements and cash flow.

The peso cost of customs duties is on the customs duties page. Dividends, intercompany loans, repatriation and the general sworn statements are on the exchange controls page. How companies and individuals obtain dollars outside the official market is on the MEP and CCL page. This page covers paying foreign suppliers of goods and services through the official market.

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. Where the rules sit in the BCRA text

some secondary summaries for this page asked for the current section numbers. They are confirmed in the index of the consolidated text updated to 14 September 2026:

Topic Location in the FX rules
Imports of goods and other purchases abroad Point 3.1, which refers to Sections 10 and 11
Rules on goods payments Section 10 (points 10.1 to 10.11)
SEPAIMPO tracking system Section 11 (points 11.1 and 11.2)
Tariff positions with special treatment Section 12 (point 12.1)
Services provided by non residents Point 3.2, which refers to Section 13 (points 13.1 to 13.6)
Interest on commercial debts for goods and services Point 3.3
Complementary requirements for every outflow Point 3.16
BOPREAL subscriptions for pre 13 December 2023 import debts Points 4.4, 4.5, 4.7 and 4.8
Definitions: related counterparties and services Points 6.6 and 6.8

2. General principles that apply to every payment

  • Only through authorised entities. All FX operations go through banks and exchange houses authorised by the BCRA. The entity must have evidence that the operation is genuine and correctly classified (points 1.1 and 1.2).
  • The boleto is a sworn statement. Every operation needs a boleto (point 1.4), and its content, including the concept code, is the client's sworn statement (point 5.3).
  • Breaches are criminal exchange offences. Point 1.5 refers them to the Criminal Exchange Regime Law (section 12 below).
  • Prior approval requests go through an authorised entity, filed at the BCRA front desk addressed to the Gerencia Principal de Exterior y Cambios, with the entity's analysis and the client's original note (point 1.8). The FX rules set no deadline for the BCRA to answer and no fee (unconfirmed).
  • External survey. The "Relevamiento de activos y pasivos externos" must be filed even if no money goes through the FX market (point 1.9). Payments of goods, services and interest check that the debt is declared "if applicable" in the last filing that has fallen due (points 3.3.1, 10.3.2.1.ix and 13.1.2).

3. What counts as an import of goods, and who can be paid

  • Customs entry. An import of goods is an operation with customs entry registered with ARCA (point 10.2.1). Customs entry means the importer has registered ("oficializado") the import declaration for release for consumption. Entry through a Solicitud Particular or courier also counts, as does entry into a free trade zone when it corresponds to a sale from a non resident to a resident. Suspensive warehouse entries and temporary imports without a currency transfer do not count (point 10.2.2).
  • What can be paid as "goods". Everything that forms part of the agreed purchase condition (the Incoterm) shown on the supplier's invoice (point 10.2.1). Costs outside that condition, such as freight paid separately under FOB, need their own boleto under the right concept (point 10.3.7).
  • Commercial debt. A debt counts as commercial import debt if it is financing from the supplier, from a foreign export credit agency, or from a foreign or local bank whose disbursement goes directly and entirely to the supplier. Leasing instalments with purchase options, assignments to a new creditor without changed terms, and refinancings by the same creditor also count (points 10.2.4.1 to 10.2.4.9). Other debts arising from imports follow the financial debt rules (point 10.2.4, last paragraph; point 10.8, concept "P13").
  • Who is the supplier. The supplier is whoever issued the commercial invoice abroad to the resident buyer. A payment to a different group company abroad is treated as a payment to the supplier if the bank has documents showing both belong to the same economic group and that the split is internal to the group (point 10.2.5).

4. Paying goods that already have customs entry (point 10.3)

The bank nominated to track the import declaration in SEPAIMPO certifies that all of the following are met, or issues a certificate so another bank can pay (point 10.3.2.1, items i to x):

  1. Proof of the customs entry of the goods.
  2. A copy of the foreign commercial invoice in the name of the resident buyer, showing the issuer's name and address, the importer, the quantity and description of goods, the sale condition and the value.
  3. A copy of the transport document (bill of lading, waybill or air waybill).
  4. Consistency between invoice, transport document and customs records.
  5. Documents that show the due date of the debt, or that it has no agreed due date.
  6. For financed operations, documents that show the financing qualifies as commercial import debt under point 10.2.4.
  7. Total payments against the declaration, including this one, do not exceed the invoiced amount.
  8. The payee is the supplier, the financing bank or credit agency, or a non resident who bought the receivable on unchanged terms.
  9. The debt is declared, if applicable, in the last external survey that has fallen due.
  10. For imports registered before 1 November 2019, a sworn statement of the outstanding balance.

In addition:

  • The currency is sold against a debit to the client's own account at a local bank (point 10.3.2.2).
  • The payment is not made before the due date of the obligation (point 10.3.2.3). Prepaying deferred commercial debt is not allowed without prior approval, except for RIGI vehicles under point 14.2.1.
  • The importer signs a sworn statement undertaking to convert, within 20 business days, any refund of import payments it receives (point 10.3.2.4).
  • The bank validates the operation in the BCRA online system at the moment of access (point 10.3.2.6).
  • Cases outside these rules need BCRA prior approval (point 10.3.2, last paragraph).
  • Timing. Deferred payments of goods with customs entry from 13 December 2023 can be made from the date of customs entry (point 10.10.1). The only carve out is the temporary import of soybeans (NCM 1201.90.00) in point 10.6.6, which must be matched by export proceeds.
  • Concept codes. The boleto uses "B06" (deferred payments of goods other than capital goods), "B22" (deferred payments of capital goods), "B15" (debts with export credit agencies or foreign banks) or "B14" (bank guarantees). It must identify the import declaration number. One boleto may cover several declarations paid to the same beneficiary, with an annex signed by the client (point 10.3.7).

5. Paying before customs entry (points 10.4, 10.5 and 10.10.2)

Payments before customs entry are advance payments, sight payments against shipping documents, payments of commercial debt where delivery has occurred but customs entry is pending, and bank guarantee payments (point 10.4.1). The bank that makes the payment tracks it until it is regularised (point 10.4.1, last paragraph; point 11.2).

Permission to pay early. Unless BCRA prior approval is obtained, the payment must fit one of the cases in point 10.10.2 (points 10.4.2.8 and 10.4.3.7). The cases most used are:

Case Rule Source
Individuals and MiPyMe: sight payments and commercial debt with customs entry pending Goods shipped from 14 April 2025; tariff position not in point 12.1 Point 10.10.2.1
Capital goods Advance payments up to 30% of FOB; advance, sight and unregistered debt together up to 80% of FOB; position not in point 12.1 Point 10.10.2.2
Bank financing funded by a foreign credit line Maturities compatible with the normal timetable Point 10.10.2.3
Simultaneous conversion of export advances or pre financing Same maturity conditions Point 10.10.2.4
Simultaneous conversion of new foreign financial debt Same maturity conditions; that debt cannot be counted for other mechanisms Point 10.10.2.5
Capital goods paid together with new foreign debt or FDI under point 7.10.2.2 Point 10.10.2.7
Debts financed or guaranteed before 13 December 2023 by banks, international organisations or official credit agencies Points 10.10.2.9, 10.10.2.10
Critical medicines through Solicitud Particular Point 10.10.2.11
Railway emergency plan goods (Decree 525/24) Certificate from the Transport Secretariat Point 10.10.2.12
Sight or unregistered debt payments not covered by 10.10.2.1, using own dollars in a local account (swap or arbitrage) or simultaneous local bank FX financing Point 10.10.2.13
Advance payment of capital goods using own dollars in a local account or local bank FX financing Point 10.10.2.14

What is a capital good. It is a good whose tariff position is classified BK in the Mercosur Common Nomenclature (Decree 690/02 and complementary rules). An operation that mixes BK and other goods also qualifies if BK goods are at least 90% of FOB and the client declares that the rest are spare parts, accessories or materials needed to run or install them (point 10.10.2, last paragraph).

Point 12.1 today. The excluded tariff list in point 12.1 now contains only aircraft positions in heading 8802. Companies that provide air navigation services are excepted (point 12.1).

Conditions for advance payments (point 10.4.2):

  • Documents showing a purchase that requires prepayment, with the goods, sale condition, delivery terms and payment terms (point 10.4.2.1).
  • The payee is the supplier (point 10.4.2.2), and the debit is to the client's own account (point 10.4.2.3).
  • A sworn statement undertaking to show customs entry within 270 calendar days for capital goods, or 90 calendar days for other goods, counted from the date of FX access. Failing that, the client must bring back and convert the refunded funds. In a mixed payment, the term follows the type of good with the larger share of value (point 10.4.2.4).
  • Related supplier. If the supplier is a related counterparty, or longer terms are needed, BCRA prior approval is required (point 10.4.2.4).
  • The bank must be satisfied the amount is reasonable given the client's import record or business plan (point 10.4.2.5).
  • New companies. For a company incorporated within the previous 365 calendar days, prior approval is needed when pending unregularised advance payments, including the new one, exceed USD 5 million (point 10.4.2.5).
  • No delays. The client must have no delayed regularisations of payments made from 2 September 2019 (point 10.4.2.6).
  • Past convictions. Prior approval is needed if the client has a conviction, or a pending criminal exchange proceeding, under art. 1 c) of Law 19.359 for import payment rules on operations before 2 September 2019. Convictions count for up to 5 years before the operation (point 10.4.2.7).
  • BCRA online validation (point 10.4.2.9).

Conditions for sight payments and unregistered commercial debt (point 10.4.3): invoice and transport document, proof that payment is due against shipping documents, payee is the supplier or the financing bank or agency, debit to own account, and a sworn statement undertaking to show customs entry within 90 calendar days of FX access or to bring the money back. A point 10.10.2 case or prior approval is still needed (point 10.4.3.7).

Regularising and extensions (point 10.5):

  • A payment is regularised by customs entry in the importer's name or a third party's (point 10.6.4), by converting the refund, by the other mechanisms in the rules, or by BCRA approval (point 10.5).
  • Tolerance of USD 10,000 a year. For undelivered balances, exchange rate differences or non delivery by the supplier, the importer may ask the tracking bank to treat the obligation as met, for up to USD 10,000 per calendar year by payment date, with a sworn statement (point 10.5.4).
  • Damaged goods. Up to five successive 180 day extensions are allowed until the insurance pays out. Foreign currency insurance proceeds must be converted within 20 business days (point 10.5.5.1).
  • Collection efforts. If the supplier defaults, the payment can be placed "in collection" with up to five successive 180 day extensions. This covers exchange controls in the supplier's country, the supplier's insolvency, or claims through credit insurers (for debts up to USD 100,000) or lawsuits (point 10.5.5.2).
  • Delays beyond the importer's control. These include production or shipping delays by the supplier, transport problems, certifications and customs proceedings. The tracking bank may extend the term up to 545 calendar days for capital goods advances and 365 calendar days for other payments, counted from FX access. Delays chosen for financial or market reasons do not qualify (point 10.5.5.3).
  • Reporting. Within 5 business days after a term expires, the tracking bank reports unregularised operations in SEPAIMPO (point 10.5.6). For bank guarantee payments, the bank must file a report ("denuncia") if customs entry is not registered within 90 days (point 10.4.4, last paragraph).

6. SEPAIMPO: the bank that follows your import (Section 11)

  • Every import declaration from 1 November 2019 is tracked. For each declaration the importer nominates a bank before ARCA, and may change it later if no unused certificates are outstanding (point 11.1).
  • The nominated bank checks that documents are consistent with customs records, that payments do not exceed the invoice, and that any financing qualifies. It issues the certificates that let any bank pay (points 11.1.1.1 to 11.1.1.4).
  • A payment certificate shows, among other data, the declaration number, the currency and amount, the next due date, the concept code, the beneficiary and its country, and the foreign bank. It is valid for 10 business days. Any certificate not returned is treated as used (point 11.1.3).
  • The nominated bank must also record events that reduce the debt without FX access. These include payments abroad with the importer's own free funds, credit notes, debt forgiveness and capitalisation of the debt. It may not charge commissions for reporting reductions (point 11.1.5).

7. Interest on commercial import debt (point 3.3)

  • Access from the due date of the interest, with the debt declared in the last survey that has fallen due if applicable (points 3.3.1 and 3.3.2).
  • Prepaying interest needs prior approval, except for RIGI vehicles under point 14.2.1 (point 3.3.2).
  • Related creditors. Interest owed to a related creditor that fell due up to 4 July 2024 needs prior approval. The exceptions are export increase or Decree 277/22 certificates, and payment made simultaneously with new foreign debt (at least 2 years of average life and 1 year of grace) or new FDI (point 3.3.3). The client may instead subscribe BOPREAL for that interest under point 4.7 (point 3.3.3, last paragraph; Com. A 8234). Interest that fell due after that date follows the general rule.

8. Services from non residents (Section 13)

What is a service. Point 6.8 follows the balance of payments concept. It includes freight, transport, travel, construction, insurance, financial services, telecommunications, information and computer services, charges for the use of intellectual property, research and development, professional and management consulting, technical and trade related services, audiovisual services and government services.

General conditions (point 13.1):

  • Documents that support the existence of the service (point 13.1.1).
  • For commercial debts, access from the due date, with the debt declared in the last external survey that has fallen due if applicable (point 13.1.2). Debts analogous to the goods categories of point 10.2.4 count as commercial. Others follow the financial debt rules.
  • Online validation in the BCRA system (point 13.1.5).
  • Otherwise, prior approval (point 13.1, last paragraph).

Timetable for services provided or accruing from 13 December 2023 (point 13.2):

Service Earliest FX access Source
S03 passenger transport, S06 travel, S23 audiovisual, S25 government, S26 traveller health assistance, S27 other health, S34 to S36 card and account debit consumption No waiting period Point 13.2.1
Banks' own ordinary expenses abroad No waiting period Point 13.2.2
S31 freight on exports, when part of the sale condition Once Customs certifies shipment Point 13.2.3
S30 freight on imports From the date the service is provided; for an SME sight payment operation under 10.10.2.1, from shipment at origin Point 13.2.4
Any other service from an unrelated provider From provision or accrual Point 13.2.5
Transfers abroad by local agents collecting for non resident providers From provision or accrual Point 13.2.5, second paragraph
Any other service from a related provider 90 calendar days after provision or accrual Point 13.2.6

The related party label sticks. The 90 day rule keeps applying even if a change of creditor or debtor means the two are no longer related (point 13.2.6, second paragraph).

Paying earlier than the timetable (point 13.3). Payment before the point 13.2 dates is allowed when:

  • it is funded by a local bank's foreign currency financing whose maturities are compatible with point 13.2. If the financing is granted before the service, terms run from the estimated service date plus 15 days (point 13.3.1);
  • it is paid together with the conversion of export advances or pre financing, or of new foreign financial debt, on the same compatible maturities (points 13.3.2 and 13.3.3);
  • it falls under the point 7.11 export mechanism (point 13.3.4);
  • the client holds a Decree 277/22 certificate (point 13.3.5);
  • the debt was financed or guaranteed before 13 December 2023 by banks, international organisations or official credit agencies (points 13.3.6 and 13.3.7);
  • it relates to a debt buyback or redemption under points 3.5.3.1 or 3.6.4.4 (point 13.3.8);
  • the provider is unrelated and the payment is made by swap or arbitrage of the client's own dollars deposited at a local bank (point 13.3.9). This route is not available for related providers;
  • it is a reinsurance premium for a RIGI project, funded by the VPU's new foreign debt (point 13.3.10; Com. A 8464).

Services provided up to 12 December 2023 need prior approval, except the no wait concepts, bank or agency financed debts, Decree 277/22 certificates, BOPREAL proceeds, the BOPREAL Series 1 windows, and the SME window (point 13.4).

9. Royalties, licences and other services to related parties

There is no separate FX regime for royalties. Licence fees, royalties, software licences, management fees, cost sharing and technical assistance charged by a foreign group company are services under point 6.8. They follow the related provider rule in point 13.2.6: payment 90 calendar days after provision or accrual.

  • Who is related. A related counterparty is one with any of the relationships described in point 1.2.2 of the BCRA rules on "Grandes exposiciones al riesgo de crédito" (point 6.6). That BCRA text is not among the project sources (unconfirmed). For the group statements of point 3.16.3.3, control is assessed under points 1.2.1.1 and 1.2.2.1 of the same rules.
  • Concept code. The FX rules list "S13. Servicios de informática" and "S15. Cargos por el uso de la propiedad intelectual" among the service concepts (point 2.2.2.2). Whether a software licence goes under S13 or S15 is not settled in the FX text. The bank and client must agree on it, because the code is a sworn statement (point 5.3) (unconfirmed).
  • Accrual date. The 90 days run from "prestación o devengamiento". For a licence billed periodically, the natural reading is the end of each billing period, but the FX rules give no specific rule (unconfirmed).
  • No swap shortcut. The own dollars route of point 13.3.9 is limited to unrelated providers.

Tax interaction. The FX timetable does not change the tax rules, and the two do not line up neatly:

  • Withholding. The payer withholds 35% of the presumed net income (ITL arts. 102 and 103). For contracts that comply with Law 22.426 on technology transfer, the presumption is 60% for technical assistance, engineering or consultancy not obtainable in the country, and 80% for licences of patents and other objects (ITL art. 104 a)). Copyright exploitation qualifies for 35%, subject to registration with the Copyright Directorate and the conditions of ITL art. 26 j) (ITL art. 104 b)). All other income is presumed at 90% (ITL art. 104 i)). The effective rates are therefore 21%, 28%, 12.25% or 31.5% of the gross payment. Tax treaties can reduce these rates.
  • Law 22.426. The law covers paid acts whose main or accessory object is the transfer, assignment or licence of technology or trademarks by persons domiciled abroad to persons domiciled in Argentina (Law 22.426, art. 1). Prior approval for parent and subsidiary contracts (art. 2) was repealed, and registration is now optional and for information only (INPI Res. 38/2026, recitals). INPI Res. 38/2026 (BO 2 February 2026) approved a new registration rulebook. Only acts whose object falls under ITL art. 104 a) 1 or 2 can be registered, and the process works on the applicant's sworn statement (Annex, items A and C). Amounts already paid before the application is filed cannot be included in the registration and certificate. Amounts accrued but unpaid, even from earlier fiscal years, can be (Annex, item J). Whether a pure software licence is "technology" under Law 22.426 and art. 104 a) 2 is a classification question the sources do not settle (unconfirmed).
  • Deduction timing. Expenses that are Argentine source income for related foreign persons can only be deducted when paid, or if payment happens before the deadline for filing the return for the year in which they accrued (ITL art. 24, last paragraph). With a 90 day FX wait, an expense accrued in the last quarter of the fiscal year can still be paid within the filing deadline, but only if the company acts promptly (unconfirmed).
  • VAT. Services performed abroad and effectively used in Argentina are taxed when the recipient is a VAT registered taxpayer (VAT Law art. 1 d)). The recipient is the taxpayer (art. 4 g)). The taxable event is the end of the service or the total or partial payment, whichever comes first (art. 5 h)). The general rate is 21% (art. 28) (unconfirmed).
  • Transfer pricing. Intercompany prices must meet arm's length rules. See the transfer pricing page.

10. The general outflow checks (point 3.16), applied to import payments

Every payment under points 3.1 to 3.3 also goes through point 3.16 (Section 3, opening paragraph). In short:

  • If ARCA lists the client in its database of apocryphal invoices, prior approval is needed (point 3.16.1).
  • The client declares that all its foreign currency in Argentina is in bank accounts, and that at the start of the day it held no more than USD 100,000 in CEDEARs and liquid foreign assets (point 3.16.2.1). Payment service provider balances and crypto assets count. Individuals paying imports are not exempt from this statement: the exemption covers only operations under points 3.8, 3.9, 3.13, 3.14.1 and 3.14.2 (point 3.16.2, last paragraph).
  • Clients that are not resident individuals declare that in the 90 calendar days before access, and undertake that for the 90 days after, they have not and will not sell securities for foreign currency settlement, swap securities for foreign assets, transfer securities abroad, buy foreign securities for pesos, buy CEDEARs, buy foreign law private debt, or hand over pesos for foreign assets (points 3.16.3.1 and 3.16.3.2). Companies also list their controllers and group and declare no peso transfers to them in the prior 90 days, except ordinary purchases of goods and services (points 3.16.3.3 and 3.16.3.4).
  • Resident individuals are not subject to point 3.16.3, because it applies only to clients that are not resident individuals (point 3.16.3, opening words).
  • Inconsistent CUIT list: enhanced checks, and the bank must refuse the operation if documents are inconsistent (point 3.16.4).

Full detail, including exclusions, is on the exchange controls page.

11. Pre December 2023 debts and BOPREAL

  • Why it matters. When the controls were reset in December 2023, importers held a large stock of unpaid commercial debt. Joint RG 5466/2023 (art. 10) created the "Padrón de Deuda Comercial por Importaciones con Proveedores del Exterior". Importers had to register debts for goods with customs entry before 13 December 2023, and for services. The term was extended to 24 January 2024 (Joint RG 5478/2024, art. 2, as noted by Infoleg). Anyone who did not register, or falsified the data, could not use the mechanisms and had their debt left "subject to later evaluation" (Joint RG 5466/2023, art. 12). Article 10 survived the abolition of SEDI (Joint RG 5651/2025, art. 1 repealed only arts. 1 to 9, 13 and 14).
  • BOPREAL. The BCRA created BOPREAL, dollar notes with a redemption option offered only to importers of goods and services, up to their unpaid imports. They have a maximum term to 31 October 2027, are subscribed in pesos at the Com. A 3500 reference rate, and pay interest up to 5% a year (Com. A 7918, 13 December 2023). Series 4 (Com. A 8233, 30 April 2025, maximum term to 31 October 2028) is open to those under points 4.4, 4.5 and 4.6. It is also open to debtors of related party interest that fell due up to 4 July 2024 on commercial import debts (Com. A 8233; Com. A 8234). The terms of each series and whether any subscription window is still open are not settled in the sources (unconfirmed).
  • Subscribing. Importers may subscribe BOPREAL up to the outstanding debt for goods registered up to 12 December 2023 (point 4.4) or services provided up to that date (point 4.5). This requires SEPAIMPO certificates or documents, the debt declared in the survey, the point 3.16 requirements, and a sworn statement that the debt is unpaid. The bank books a boleto under "B26" (goods) or "S33" (services) at the BOPREAL face value (points 4.4 and 4.5).
  • Using BOPREAL proceeds. BOPREAL principal and interest collected in dollars can be applied, by swap or arbitrage, to pay the eligible debts (point 4.8.1). Primary subscribers can disregard the sale of their BOPREAL for dollars in the 90 day statements, up to the amount subscribed (point 4.8.2).
  • Series 1 windows. Clients who subscribed BOPREAL Series 1 before 31 January 2024 for at least 50% (or 25%) of their eligible debts may pay part of the rest under conditions linked to export proceeds (points 4.8.4 and 4.8.5).
  • SME window. Individuals and MiPyMe with total pre 13 December 2023 import debts of goods and services pending at 24 January 2024 of USD 500,000 or less, all registered in the padrón, may pay them without prior approval. Total payments across banks may not exceed the registered amount (points 10.11.7 and 13.4.8).

12. Penalties: the Criminal Exchange Regime Law 19.359

Point 1.5 of the FX rules says breaches fall under the Criminal Exchange Regime Law. That is Law 19.359 (BO 10 December 1971), consolidated by Decree 480/1995 (BO 25 September 1995). The Infoleg list of amending norms shows no later change to the text of the offences or penalties (Infoleg list of norms modifying Law 19.359, checked 26 October 2026).

Offences (art. 1): FX dealings without an authorised entity; operating in exchange without authorisation; any false declaration related to FX operations; failure to correct declarations when the real operations differ; any FX operation not made for the amount, currency, rate, terms and other conditions set by the rules; and any act or omission that breaches the exchange regime.

Penalties (art. 2):

Situation Penalty Source
First offence Fine of up to 10 times the amount of the operation Art. 2 a)
First repeat offence Prison 1 to 4 years, or fine of 3 to 10 times the amount Art. 2 b)
Second repeat offence Prison 1 to 8 years and the maximum fine Art. 2 c)
Where the first fine was not above 3 times the amount Prison under b) reduced to 1 month to 4 years Art. 2 d)
Additional Suspension up to 10 years or cancellation of FX authorisation, and disqualification up to 10 years from acting as importer, exporter, FX broker or in FX entities Art. 2 e)
Companies The company is also sanctioned when directors, legal representatives, managers, statutory auditors or supervisory board members act in its name or for its benefit. The fine is joint and several on the company and on the individuals involved Art. 2 f)
Spontaneous correction of a false declaration within 15 days Fine reduced to one quarter, and not counted for repeat offences Art. 2 g)
Several independent offences Fines are added, capped at 10 times the largest operation Art. 3

Procedure and powers:

  • The BCRA investigates. It can demand information, inspect books and request search warrants (art. 5).
  • Records must be kept for at least 10 years, and the BCRA may limit inspections to operations in the prior 6 years (art. 5).
  • The BCRA runs the summary proceeding, which may not exceed 360 business days from the opening resolution. The case then goes to the criminal economic court in Buenos Aires or the federal court in the province (art. 8).
  • Price checks. For estimates, the BCRA may presume, unless the importer proves otherwise, a link between the importer and the foreign exporter when the declared import price differs from the wholesale price at origin plus allowable costs (art. 13 b)).
  • Precautionary measures. These can hit an importer hard. The BCRA may refuse FX authorisations, refuse to process customs release requests, refuse shipping permits and suspend registrations of those under inspection or investigation (art. 17 a)). It may also bar travel abroad by those investigated (art. 17 b)).
  • Repeat offences count convictions within 5 years (art. 18). The action is time barred after 6 years, with interruptions (art. 19).

Separately, a past conviction or pending proceeding under art. 1 c) for import payment rules can force BCRA prior approval for new advance payments (point 10.4.2.7). False data in the old debt padrón carried administrative sanctions (Joint RG 5466/2023, art. 10).

Step by step

A. Importing and paying goods

  1. Classify the goods and check the payment route. Find the NCM code and check whether it is BK (capital good) and whether it appears in point 12.1 (today only aircraft). Check whether your company qualifies as MiPyMe under the BCRA rules on "Determinación de la condición de micro, pequeña y mediana empresa" (unconfirmed).
  2. Agree payment terms with the supplier that fit the FX timetable. For example: 30% advance, 50% against shipping documents, 20% at 60 days. For a related supplier, avoid advance payments unless you are prepared to seek prior approval (point 10.4.2.4).
  3. Check your 90 day history. Before any FX access, make sure neither the company nor its group has sold securities for dollars (MEP or CCL), bought CEDEARs or done the other operations in point 3.16.3.1 in the prior 90 days, and plan not to do so for 90 days after. See MEP and CCL.
  4. Check the external survey. Confirm that your foreign debts and assets are declared in the last filing that has fallen due (points 1.9, 10.3.2.1.ix). From 2026 data, companies below USD 10 million of external assets and liabilities file annually within 90 days of year end (Com. A 8304) (unconfirmed).
  5. Advance or sight payment (if any). Give the bank the pro forma or purchase order showing the prepayment terms (advance), or the invoice and transport document (sight). Sign the undertaking to show customs entry within 270 or 90 days (points 10.4.2.4, 10.4.3.6) and the point 3.16 statements. The bank validates online, debits your peso account, sells the currency and transfers it. It generates a unique tracking number (point 10.4.5).
  6. Customs clearance. Your customs broker registers the import declaration in the Malvina system. When registering, nominate the SEPAIMPO bank (point 11.1). Taxes are paid at customs. See customs duties.
  7. Regularise prior payments. Ask the SEPAIMPO bank for the certificate assigning the declaration to the earlier advance or sight payments (points 10.5.1, 11.1.4). Do this before the 90 or 270 day term runs out.
  8. Pay the balance. On or after the due date, and from customs entry, ask the SEPAIMPO bank for a payment certificate, valid for 10 business days (point 11.1.3). Pay through that bank or another. Provide the invoice, transport document and point 3.16 statements, and sign the refund conversion undertaking (point 10.3.2.4). Use concept B06, or B22 for capital goods (point 10.3.7).
  9. Pay freight separately if it is outside the sale condition (concept S30), from the date the service is provided, or from shipment for an SME sight payment operation (point 13.2.4).
  10. Report anything that reduces the debt without FX access, such as credit notes, payments abroad from your own free funds or capitalisation, to the SEPAIMPO bank (point 11.1.5).
  11. Keep everything for at least 10 years (Law 19.359, art. 5).

B. Paying a foreign service

  1. Document the service. You need a contract or order, an invoice and evidence the service was rendered (point 13.1.1). For royalties, licences and technical assistance, decide whether to register the contract with INPI before the first payment (INPI Res. 38/2026, Annex, item J).
  2. Establish whether the provider is related (point 6.6). If it is, diarise the date 90 calendar days after each accrual (point 13.2.6).
  3. Assess the taxes. Compute the income tax withholding (ITL arts. 102 to 104, or the applicable treaty) and the reverse charge VAT (VAT Law arts. 1 d), 4 g), 5 h)). Agree with the provider whether the price is gross or net of withholding. If net, the grossing up rules apply (Income Tax Regulations, art. 227, referred to in INPI Res. 38/2026, Annex, item J) (unconfirmed).
  4. Check the external survey and the 90 day history, as for goods.
  5. Instruct the bank on or after the due date and the point 13.2 date. Supply documents, the concept code and the point 3.16 statements. The bank validates the payment in the BCRA online system (point 13.1.5).
  6. Withhold and deposit the income tax with ARCA (unconfirmed), and pay the VAT (unconfirmed).
  7. Keep the file (Law 19.359, art. 5).

C. Asking for BCRA prior approval

  1. Write a note to your bank explaining the operation, why it needs approval (for example, an advance payment to a related supplier) and the supporting documents.
  2. The bank analyses how the operation fits the rules, checks every other requirement and files the request at the BCRA front desk, addressed to the Gerencia Principal de Exterior y Cambios (point 1.8).
  3. No response time is set in the rules (unconfirmed).

Costs and timelines

Rates, thresholds and limits

Item Figure USD or ARS equivalent at MEP (unconfirmed) Source
Waiting period, goods with customs entry from 14 Apr 2025 0 days from customs entry n/a Point 10.10.1; Com. A 8226, pt 7
Capital goods advance payments Up to 30% of FOB n/a Point 10.10.2.2 i)
Capital goods advance, sight and unregistered debt combined Up to 80% of FOB n/a Point 10.10.2.2 ii)
BK share needed for a mixed shipment to count as capital goods At least 90% of FOB n/a Point 10.10.2, last paragraph
New company (up to 365 days old): pending advance payments needing prior approval Above USD 5,000,000 ARS 7,819,500,000 Point 10.4.2.5
Annual tolerance for undelivered balances or supplier default USD 10,000 per calendar year ARS 15,639,000 Point 10.5.4
Credit insurer or agency collection route Debts up to USD 100,000 ARS 156,390,000 Point 10.5.5.2 iii) a)
SME window for pre 13 Dec 2023 debts Total debts up to USD 500,000 ARS 781,950,000 Points 10.11.7.1, 13.4.8
Liquid foreign assets ceiling for any outflow USD 100,000 ARS 156,390,000 Point 3.16.2.1
Related party services waiting period 90 calendar days n/a Point 13.2.6
Unrelated services waiting period 0 days from provision or accrual n/a Point 13.2.5
BOPREAL interest (Series under Com. A 7918) Up to 5% a year n/a Com. A 7918
Income tax withholding on foreign beneficiaries 35% of presumed net income n/a ITL arts. 102, 103
Presumed net income: technical assistance (Law 22.426 compliant, not obtainable locally) 60% (effective 21%) n/a ITL art. 104 a) 1
Presumed net income: licences of patents and other objects (Law 22.426 compliant) 80% (effective 28%) n/a ITL art. 104 a) 2
Presumed net income: registered copyright exploitation 35% (effective 12.25%) n/a ITL art. 104 b)
Presumed net income: lease of movable goods 40% (effective 14%) n/a ITL art. 104 f)
Presumed net income: other income 90% (effective 31.5%) n/a ITL art. 104 i)
VAT on imported services (registered recipient) 21% n/a VAT Law arts. 1 d), 28
Criminal exchange fine, first offence Up to 10 times the operation n/a Law 19.359, art. 2 a)

Deadlines

Obligation Term Source
Show customs entry after an advance payment of capital goods 270 calendar days from FX access Point 10.4.2.4
Show customs entry after an advance payment of other goods 90 calendar days from FX access Point 10.4.2.4
Show customs entry after a sight or unregistered debt payment 90 calendar days from FX access Point 10.4.3.6
Extension for causes beyond the importer's control Up to 545 days (capital goods advances) or 365 days (others) from access Point 10.5.5.3
Extensions for damaged goods or collection efforts Up to five successive periods of 180 days Points 10.5.5.1, 10.5.5.2
Register customs entry when payment was financed under 10.10.2.3 15 calendar days from arrival or from the financing Point 10.10.2.3 ii)
Convert refunds of import payments 20 business days Point 10.3.2.4
Convert foreign currency insurance or collection proceeds 20 business days Points 10.5.5.1 v), 10.5.5.2
SEPAIMPO payment certificate validity 10 business days Point 11.1.3
Bank reports unregularised payment in SEPAIMPO 5 business days after the term expires Point 10.5.6
Pay deferred commercial debt Not before its due date Point 10.3.2.3
Pay interest on commercial debt From its due date Point 3.3.2
Related party services 90 calendar days after provision or accrual Point 13.2.6
Cross restriction for companies 90 calendar days before and after access Points 3.16.3.1, 3.16.3.2
External survey, secondary sample (below USD 10 million), data from 2026 Annual, 90 calendar days after year end Com. A 6401 Annex pt 6, as replaced by Com. A 8304
External survey, main sample (USD 10 million or more), data from 2026 Quarterly within 45 days; annual within 180 days Com. A 6401 Annex pts 2 and 6, as replaced by Com. A 8304
INPI observations on a technology contract 30 calendar days, extendable automatically three times INPI Res. 38/2026, Annex, item M
Spontaneous correction of a false FX declaration 15 days Law 19.359, art. 2 g)
Criminal exchange action time bar 6 years Law 19.359, art. 19
Record keeping for FX operations At least 10 years Law 19.359, art. 5

How the timetable changed

Period Goods with customs entry Related services Unrelated services Source
Up to 12 Dec 2023 debts Prior approval, with BOPREAL and SME exits Prior approval, with exits Prior approval, with exits Points 10.11, 13.4
Customs entry from 21 Oct 2024 (text in force Feb 2025) 30 calendar days after customs entry (energy goods from entry) 180 days 30 days Com. A 8191 text, points 10.10.1, 13.2.6, 13.2.7
From 14 Apr 2025 to date From customs entry (0 days) 90 days From provision Com. A 8226, pts 7, 10, 11; current points 10.10.1, 13.2.5, 13.2.6

The intermediate stepped schedules that applied between 13 December 2023 and 20 October 2024 are no longer in the consolidated text, which notes they have all run out (Com. A 8191, cover note) (unconfirmed).

Timeline of norms

BCRA communications are dated by the BCRA. Their BO publication dates are not in the project sources (unconfirmed).

Norm Date Content
Law 19.359, Criminal Exchange Regime BO 10 Dec 1971 Offences and penalties (t.o. Decree 480/1995, BO 25 Sep 1995)
Law 22.426, Technology transfer BO 23 Mar 1981 Registration of technology and trademark contracts with foreign licensors
Law 27.541, PAIS tax, Chapter 6 In force from 23 Dec 2019 PAIS tax for five fiscal periods (art. 35)
Joint RG 5271/2022 11 Oct 2022 SIRA and SIRASE (repealed)
Com. A 7918 13 Dec 2023 BOPREAL created
Joint RG 5466/2023 Signed 22 Dec 2023; BO 26 Dec 2023 SEDI replaces SIRA; SIRASE falls with RG 5271; debt padrón created
Com. A 7925 22 Dec 2023 BOPREAL rules in the FX text
Joint RG 5478/2024 BO 10 Jan 2024 Padrón deadline extended to 24 Jan 2024
Decree 777/2024 30 Aug 2024 Reduced PAIS rate for import cases d) and e) of Decree 99/2019, art. 13 bis
PAIS tax expires 22 Dec 2024 Last day of application
Com. A 8191 10 Feb 2025 Consolidated text: goods 30 days after customs entry; services 30 and 180 days
Joint RG 5651/2025 Signed 24 Feb 2025; BO 25 Feb 2025; effective 26 Feb 2025 SEDI abolished; pending SEDI declarations lapse
Com. A 8226 11 Apr 2025; effective 14 Apr 2025 Goods payable from customs entry; SME sight payments; capital goods 30% and 80%; services 0 and 90 days
Com. A 8233 and A 8234 30 Apr 2025 BOPREAL Series 4; BOPREAL for related party debts
RG 5720/2025 (ARCA) BO 7 Jul 2025 Refund of unused PAIS prepayments as import duty credit
Com. A 8304 19 Aug 2025 New external survey samples and deadlines from 2026 data
RG 5765/2025 (ARCA) BO 26 Sep 2025 PAIS refund register reopened (6 Oct to 19 Nov 2025)
INPI Res. 38/2026 Signed 29 Jan 2026; BO 2 Feb 2026 New rulebook for registering technology transfer contracts
INPI DTT Disposición 63/2026 Listed by Infoleg with date 11 Feb 2026 New registration form (unconfirmed)
Com. A 8426 23 Apr 2026 RIGI adjustments, including import financings counted for the VPU
Com. A 8464 6 Aug 2026 Reinsurance payments for RIGI projects (point 13.3.10)
Com. A 8481 14 Sep 2026 Updated consolidated text, basis of this page

Worked examples

Facts. A metalworking SA that qualifies as MiPyMe (unconfirmed) buys a CNC machine from an unrelated Italian manufacturer. Its tariff position is classified BK and is not in point 12.1. FOB price USD 200,000. Ocean freight USD 8,000, paid separately to a foreign forwarder. Insurance equal to USD 1,000, taken with a local insurer in pesos. Payment terms are 30% with the order, 50% against shipping documents and 20% at 60 days from the bill of lading. The company has not traded securities for dollars in the last 90 days and holds no foreign assets. It files the external survey on time.

Payment timeline and FX route

Date (2026) Event Amount USD ARS at MEP (unconfirmed) FX route and check
2 Feb Advance with the order 60,000.00 93,834,000.00 Capital goods advance up to 30% of FOB (point 10.10.2.2 i)). Undertaking to show customs entry within 270 days, by 30 Oct 2026 (point 10.4.2.4)
15 Apr Sight payment against bill of lading 100,000.00 156,390,000.00 SME sight payment (point 10.10.2.1). The capital goods 80% route also works: 60,000 + 100,000 = 160,000 = 80% of FOB (point 10.10.2.2 ii)). Undertaking to show customs entry within 90 days, by 14 Jul 2026 (point 10.4.3.6)
15 Apr Freight to forwarder (S30) 8,000.00 12,511,200.00 From shipment, because the operation fits point 10.10.2.1 (point 13.2.4)
25 May Customs entry registered; SEPAIMPO bank nominated n/a n/a Point 11.1
25 May onwards Advance and sight payments assigned to the declaration n/a n/a Points 10.5.1, 11.1.4
14 Jun Balance due (60 days after bill of lading) 40,000.00 62,556,000.00 Deferred payment from customs entry (point 10.10.1), not before due date (point 10.3.2.3), concept B22 (point 10.3.7)
Total paid abroad 208,000.00 325,291,200.00

Customs taxes at clearance. The figures follow the method on the customs duties page and the same assumptions it uses for capital goods. Customs uses its own exchange rate (Customs Code, art. 639).

Item Calculation USD ARS at MEP (unconfirmed)
Customs value (CIF) 200,000 + 8,000 + 1,000 209,000.00 326,855,100.00
Import duty 2% capital goods list rate 4,180.00 6,537,102.00
Statistics fee 3% of 209,000, below the band cap (Decree 1140/2024, art. 1) (unconfirmed) 6,270.00 9,805,653.00
VAT base 209,000 + 4,180 + 6,270 219,450.00 343,197,855.00
Import VAT 10.5% (unconfirmed) 23,042.25 36,035,774.77
VAT and income tax perceptions Excluded for capital goods for own use, declared as such (RG 2937, art. 2 c); RG 2281, art. 3, point 3) 0.00 0.00
Paid at customs 33,492.25 52,378,529.78

Total cash and real cost

USD ARS at MEP (unconfirmed)
Paid abroad (machine and freight) 208,000.00 325,291,200.00
Local insurance 1,000.00 1,563,900.00
Paid at customs 33,492.25 52,378,529.78
Total cash out 242,492.25 379,233,629.78
Less import VAT recoverable as input tax (23,042.25) (36,035,774.77)
Cost before bank charges, broker and port fees 219,450.00 343,197,855.00

What the example shows.

  • The company paid 80% of the price before the machine reached Argentina, without BCRA approval, because the machine is a capital good and the buyer is an SME. A large company buying the same machine could still prepay 30% and pay up to 80% in total under the capital goods route (point 10.10.2.2). A large company buying non capital goods could not pay before customs entry at all, except through financing or own dollar routes (points 10.10.2.3 to 10.10.2.14).
  • Two separate clocks run: 14 July 2026 for the sight payment and 30 October 2026 for the advance. Customs entry on 25 May meets both, but only once the SEPAIMPO assignment is recorded. A customs delay of two months would have broken the 90 day clock on the sight payment. The bank could have extended it only for causes beyond the importer's control (point 10.5.5.3).
  • Cost to do it: no BCRA fee; bank FX commissions and SWIFT fees (unconfirmed); customs broker and port charges (unconfirmed); time from order to final payment in this example about 4.5 months.

Facts. Argentine SRL, wholly owned by a foreign parent, uses the parent's ERP software under an intercompany licence. The fee is USD 30,000 per calendar quarter, invoiced on the last day of each quarter and due 30 days later. The parent is a related counterparty (point 6.6). The SRL is VAT registered. Assume no treaty reduction applies (unconfirmed). Assume the licence qualifies as a licence of "other objects" under ITL art. 104 a) 2, and the contract is registered with INPI before any payment (unconfirmed).

Step 1: FX timetable (point 13.2.6). The contractual due date is 30 days after the invoice, but the FX rules only allow access 90 days after accrual. The later of the two dates governs (points 13.1.2 and 13.2.6).

Quarter (accrual date) Contract due date Earliest FX access (accrual + 90 calendar days)
Q1 2026 (31 Mar 2026) 30 Apr 2026 29 Jun 2026
Q2 2026 (30 Jun 2026) 30 Jul 2026 28 Sep 2026
Q3 2026 (30 Sep 2026) 30 Oct 2026 29 Dec 2026
Q4 2026 (31 Dec 2026) 30 Jan 2027 31 Mar 2027

If the licensor were an unrelated software vendor, each quarter could be paid on its contractual due date (point 13.2.5). The SRL could even pay with its own dollars held at a local bank (point 13.3.9).

Step 2: taxes per quarter (fee stated gross)

Item Calculation USD ARS at MEP (unconfirmed)
Gross licence fee 30,000.00 46,917,000.00
Income tax withheld, INPI registered (art. 104 a) 2) 35% × 80% × 30,000 = 28% 8,400.00 13,136,760.00
Net transferred to parent 30,000 − 8,400 21,600.00 33,780,240.00
Alternative: not registered or not qualifying (art. 104 i)) 35% × 90% × 30,000 = 31.5% 9,450.00 14,778,855.00
Net transferred in that case 30,000 − 9,450 20,550.00 32,138,145.00
Reverse charge VAT (art. 1 d)), creditable (unconfirmed) 21% × 30,000 6,300.00 9,852,570.00

If the contract says the fee is net of Argentine tax, the SRL bears the tax. On a simple grossing up at the 28% rate, the gross amount is 30,000 ÷ (1 − 0.28) = USD 41,666.67 (ARS 65,162,500.00), and the withholding is USD 11,666.67 (ARS 18,245,500.00) (unconfirmed).

Step 3: annual picture (gross fee contract, INPI registered)

USD ARS at MEP (unconfirmed)
Licence fees for 2026 120,000.00 187,668,000.00
Withholding deposited with ARCA 33,600.00 52,547,040.00
Reverse charge VAT (creditable) 25,200.00 39,410,280.00
Bought in the FX market and sent to parent 86,400.00 135,120,960.00

What the example shows.

  • INPI timing matters. Filing with INPI before the first payment allows all amounts to be certified. Payments made before filing cannot be included (INPI Res. 38/2026, Annex, item J). The difference between 28% and 31.5% on USD 120,000 a year is USD 4,200 (ARS 6,568,380).
  • Withholding may be due before the dollars can leave. For withholding purposes, ITL art. 102 treats as payment the situations listed in ITL art. 24, which include amounts credited to the beneficiary's account, reinvested, capitalised or otherwise disposed of with its consent (ITL art. 24, paragraph on when expenses are deemed paid) (unconfirmed). If the SRL credits the parent's intercompany account when the invoice is booked, withholding may arise then, even though the dollars can only be bought 90 days later (unconfirmed).
  • Deduction timing. The Q4 2026 fee accrues on 31 December 2026 and can only be paid through the FX market from 31 March 2027. It is deductible in the 2026 return only if paid before that return's filing deadline (ITL art. 24, last paragraph) (unconfirmed).
  • Cost to do it: no BCRA fee; INPI registration fee (unconfirmed); bank FX charges (unconfirmed); an average 90 day delay in each remittance.

Practical traps

  1. "From customs entry" is not "before due date". Point 10.10.1 lets you pay from customs entry, but point 10.3.2.3 forbids paying before the debt's own due date. You cannot shorten agreed supplier credit just because you have pesos.
  2. The two regularisation clocks. An advance payment of capital goods has 270 days to be matched by customs entry. A sight payment has only 90 days (points 10.4.2.4 and 10.4.3.6). Both run from the FX access date, not from shipment.
  3. Advance payments to a related supplier need prior approval (point 10.4.2.4), even for capital goods within the 30% limit. Sight payments against shipping documents have no equivalent related party clause in point 10.4.3, but still need a point 10.10.2 route (unconfirmed).
  4. The MEP or CCL trap. If the company, or any company in its group, buys dollars through a securities trade settled in foreign currency, it may not access the official market for import payments for the next 90 days, and vice versa (points 3.16.3.1 and 3.16.3.2). This is the most common way companies lose access. See MEP and CCL.
  5. Pay from your own account. The pesos must be debited from the importer's own account at a local bank (points 10.3.2.2, 10.4.2.3, 10.4.3.5). Third party funding breaks the rule.
  6. Payee mismatch. Paying a group company of the supplier needs proof that both are in the same group and that the split is internal (point 10.2.5). Paying a trader or agent that did not issue the invoice does not fit.
  7. Freight under FOB is a service. It needs its own boleto (point 10.3.7) and follows point 13.2.4.
  8. Do not prepay interest. Prepaying interest on commercial debt needs prior approval (point 3.3.2).
  9. The label "related" never wears off. Selling the licensor out of the group does not end the 90 day wait for services already provided (point 13.2.6).
  10. The own dollars shortcut is for unrelated providers only (point 13.3.9). For goods, the own dollars swap applies to sight payments and unregistered debt (point 10.10.2.13) and to capital goods advances (point 10.10.2.14).
  11. A cross reference that does not exist. Point 13.3 refers to "points 13.2.3 to 13.2.7", but point 13.2 now ends at 13.2.6. Earlier texts had a 13.2.7 for related services (Com. A 8191 text). The intended reading appears to be points 13.2.3 to 13.2.6 (unconfirmed).
  12. New companies with big prepayments. For a company up to 365 days old, pending advance payments above USD 5 million need prior approval (point 10.4.2.5). Plan a start up's first imports accordingly.
  13. Refunds must come home. Any refund of an import payment must be converted within 20 business days (point 10.3.2.4). Keeping a supplier credit note abroad and using it later must be reported to the SEPAIMPO bank (point 11.1.5).
  14. Survey filings. A missed external survey filing blocks payments (points 3.3.1, 10.3.2.1.ix, 13.1.2). The 2026 regime changes samples and deadlines (Com. A 8304).
  15. Concept codes are sworn statements. Coding a related party fee as a no wait concept, or a service as goods, is a false declaration under Law 19.359, art. 1 c). A spontaneous correction within 15 days cuts the fine to a quarter (art. 2 g)).
  16. INPI after payment is too late for amounts already paid (INPI Res. 38/2026, Annex, item J).
  17. Old debts are still blocked. Pre 13 December 2023 debts that were never registered in the padrón cannot use the SME window (points 10.11.7.2 and 13.4.8 ii)), and Joint RG 5466/2023, art. 12 leaves them "subject to later evaluation".
  18. Precautionary measures reach customs. A BCRA investigation can lead to refusal of customs release requests (Law 19.359, art. 17 a) 2)).

Recent changes

  • 26 February 2025. SEDI abolished. Pending SEDI declarations lapsed. The debt padrón (art. 10 of Joint RG 5466/2023) survives (Joint RG 5651/2025, arts. 1 and 2, BO 25 February 2025).
  • 14 April 2025 (Com. A 8226, 11 April 2025). All goods with customs entry from 14 April 2025 are payable from customs entry (point 7). New SME sight payments for goods shipped from 14 April 2025 (point 8). Capital goods advances up to 30% and combined early payments up to 80% of FOB (point 9). Unrelated services payable from provision (point 10). Related services payable after 90 days (point 11). Point 10.6.7 removed (point 12).
  • 30 April 2025 (Com. A 8233, A 8234). BOPREAL Series 4 and its use for related party commercial interest that fell due up to 4 July 2024.
  • 7 July and 26 September 2025 (RG 5720/2025, RG 5765/2025). Refund of unused PAIS prepayments as a credit against import duties, in 1 to 24 monthly instalments depending on the amount (RG 5720/2025, art. 4). The register was reopened from 6 October to 19 November 2025 for imports with customs entry up to 12 December 2023, and for later imports up to 24 November 2024 where the prepayment could not be used (RG 5765/2025, arts. 1 and 3).
  • 19 August 2025 (Com. A 8304). New external survey samples and deadlines from first quarter 2026 data.
  • 2 February 2026 (INPI Res. 38/2026). Simplified, sworn statement based registration of technology transfer contracts. Pre filing payments are excluded from the certificate.
  • 6 August 2026 (Com. A 8464). Early payment route for reinsurance of RIGI projects (point 13.3.10).
  • 14 September 2026 (Com. A 8481). Updated consolidated text, the basis of this page. No later CAMEX circular found up to 22 October 2026 (project probe note).

Pending changes

  • Related party services. The 90 day rule remains. No source in the project announces a change.
  • Section 12 and point 12.1. Only aircraft positions remain. The BCRA could reintroduce positions [no source].
  • Point 13.3 cross reference to a non existent point 13.2.7 (unconfirmed).
  • MiPyMe status depends on the BCRA rules on determining SME status, which are not in the sources (unconfirmed).
  • External survey 2026 regime. The first annual filing for the secondary sample under the new rules, for 2026 data, falls 90 days after 31 December 2026, that is 31 March 2027 (Com. A 8304) (unconfirmed).
  • BOPREAL. Series 1 matures by 31 October 2027 at the latest (Com. A 7918) and Series 4 by 31 October 2028 (Com. A 8233). Holders using proceeds to pay old debts should track redemption dates (unconfirmed).
  • INPI form. DTT Disposición 63/2026 approved a new form (unconfirmed).
  • Withholding versus FX timing on intercompany accounts (unconfirmed).
  • BCRA response times for prior approvals are not regulated (unconfirmed).

FAQ

1. Do I still need SIRA, SIRASE or SEDI approval to import or pay a foreign supplier? No. SEDI, which replaced SIRA, was abolished from 26 February 2025 and pending declarations lapsed (Joint RG 5651/2025). SIRASE fell with the repeal of Joint RG 5271/2022 (Joint RG 5466/2023, art. 15). Technical and licence requirements for specific goods (LPCO) are separate and still apply. See the customs duties page.

2. When can I pay for goods that have cleared customs? From the date of customs entry, for any goods registered from 14 April 2025, and not before the debt's due date (points 10.10.1 and 10.3.2.3). The only exception is the soybean temporary import regime (point 10.6.6).

3. Can I pay my supplier in advance? Yes, in these cases: for capital goods up to 30% of FOB, if you use own dollars or eligible financing, or with BCRA prior approval (points 10.10.2.2, 10.10.2.3 to 10.10.2.14, 10.4.2.8). SMEs and individuals can pay at sight against shipping documents (point 10.10.2.1), but an advance before shipment is not a sight payment. Advance payments to a related supplier always need prior approval (point 10.4.2.4).

4. How long does my subsidiary have to wait to pay royalties or management fees to the parent? Ninety calendar days from the date the service is provided or accrues (point 13.2.6). The parent's invoice date and contract terms do not shorten that.

5. Is the PAIS tax still charged on imports? No. It applied from 23 December 2019 to 22 December 2024 inclusive (as recited in RG 5720/2025) and expired with its five fiscal period term (Law 27.541, art. 35). Unused PAIS prepayments made at customs could be refunded as a credit against import duties through the RG 5720/2025 and RG 5765/2025 registers, whose windows closed on 4 September 2025 and 19 November 2025.

6. We still owe a supplier for goods imported in 2023. Can we pay now? Only with BCRA prior approval, unless you fit an exception. The exceptions are BOPREAL subscriptions and proceeds, the SME window for total old debts up to USD 500,000 registered in the padrón, debts financed or guaranteed by banks or official credit agencies before 13 December 2023, or Decree 277/22 certificates (point 10.11).

7. Can I pay the supplier with dollars I already have? Yes in several cases. Own dollars deposited at a local bank can be applied by swap or arbitrage to sight payments and unregistered debt for goods (point 10.10.2.13), to capital goods advances (point 10.10.2.14) and to services from unrelated providers (point 13.3.9). Payments abroad from your own free funds must be reported to the SEPAIMPO bank (point 11.1.5.2). If you obtained those dollars by selling securities, the 90 day cross restriction still applies to later official market access (point 3.16.3).

8. What happens if the goods never arrive after I prepaid? You must either show customs entry within the term (90 or 270 days) or bring back and convert the refund (point 10.4.2.4). The bank can grant extensions for causes beyond your control, for damaged goods or for collection efforts against the supplier (points 10.5.5.1 to 10.5.5.3). Up to USD 10,000 a year can be written off with a sworn statement (point 10.5.4). Otherwise the bank reports you in SEPAIMPO within 5 business days (point 10.5.6), and you cannot make new advance payments while the delay lasts (point 10.4.2.6).

9. What are the penalties for getting it wrong? Under Law 19.359, a first offence carries a fine of up to 10 times the operation, and repeat offences can carry prison. The company and its directors and managers can be jointly liable for the fine (art. 2). The BCRA can also block FX authorisations and customs release during an investigation (art. 17). Correcting a false declaration within 15 days cuts the fine to a quarter (art. 2 g)).

10. Does my bank charge a fee or need BCRA approval for each payment? No BCRA approval is needed when the payment fits the rules. The bank validates it in the BCRA online system (points 10.3.2.6 and 13.1.5). Bank fees are commercial (unconfirmed).

11. Does registering our licence with INPI change the FX timing? No. INPI registration affects the income tax withholding presumption (ITL art. 104 a); INPI Res. 38/2026). The FX timing for a related licensor is 90 days in any case (point 13.2.6).

12. Are individuals importing goods subject to the 90 day securities restriction? No. Point 3.16.3 applies only to clients that are not resident individuals. Individuals still sign the USD 100,000 liquid foreign assets statement for import payments (point 3.16.2). Their own savings purchases carry a separate 90 day undertaking (point 3.8.5), covered on the exchange controls page.

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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