The Revenue and Customs Control Agency expanded the tax compensation regime
Tax credits may arise from official assessments, sworn statements, or administrative and judicial resolutions. Now, all these scenarios allow the use of balances in tax compensation, avoiding cash payments and simplifying tax management.
With General Resolution 5753/2025, published in the Official Gazette, ARCA introduced a key modification for substitute taxpayers.
Since September 5, those who perform collection and payment functions on behalf of third parties will be able to use freely available credit balances originating from their own sworn statements.
The regulation allows taxes to be settled directly through the Tax Accounts System, available on ARCA's website. The central condition is that the beneficiary of the tax credit and the responsible taxpayer must be the same person. In addition, the credits applied must be liquid and enforceable, which ensures transparency and security in the process.
The measure expands the scope of the compensation regime and eliminates previous restrictions. With this resolution, General Resolutions 1,658, 3,175, 4,334, and 4,521 were repealed, which limited substitute taxpayers and those responsible for third-party debts from accessing this operation.
The implementation of the Tax Accounts System enables digital and self-managed administration, reducing time and bureaucracy. This represents a change from the traditional operation, which required separate procedures and review by the tax authority.
ARCA also established a five-year statute of limitations for applicable balances. After that period, credits expire as a compensation option, which aims to keep the tax record up to date and eliminate historical credits.
With this modification, the agency aims to facilitate tax regularization, improve the use of tax credits, and streamline the administration of tax resources, in line with a more modern and efficient management policy.
