Argentina establishes procedures for the use of BOPREALs against tax and customs liabilities

General Resolution No. 5675 (the Resolution), published in the Official Gazette on 16 April 2025, allows "Bonds for the Reconstruction for a Free Argentina" (Bonos para la Reconstruccion de una Argentina Libre, abbreviated as BOPREAL) Series 1A, 1B and 1C to be used to cancel tax and customs obligations. The BOPREALs must be irrevocably transferred to the Revenue and Customs Control Agency (Agencia de Recaudacion y Control Aduanero, abbreviated ARCA).

Background

Decree No. 72, issued on 21 December 2023, established that the BOPREALs could be used for the cancellation — at their technical value — of tax (e.g., income tax or value-added tax) and customs obligations, plus interest and fines. The BOPREALs cannot be used to pay Social Security taxes, tax on debits and credits, or certain other taxes. (For background, see EY Global Tax Alert, Argentina to issue 'Bonds for the reconstruction for a Free Argentina', dated 10 January 2024.)

Use of BOPREALs under the Resolution

Caja de Valores — which functions as Central Depository Agent for Negotiable Securities, and Custody, Registration and Payment Agent in Argentina — will issue form No. 1400, providing necessary data for each bond. BOPREALs will be transferred to ARCA, which will be informed of the details of the transfer through the submitted form No. 1400.

ARCA will register the BOPREALs as a credit for the taxpayer, who will ultimately allocate the credit to the obligation to be cancelled.

Once the BOPREALs are transferred to the ARCA, they cannot generate a credit or a refund.

Implications

Argentine taxpayers holding BOPREALs Series 1A, 1B and 1C could use them to pay tax and customs liabilities.