Last week, Congress approved and enacted a Short Law to rectify certain aspects of the Tax Compliance Law (Law 21,713) that was enacted in October 2024. The modifications introduced are as follows:
- The Tax Compliance Law omitted, due to a transcription error, the new anti-avoidance provisions that had been approved by Congress. The Short Law corrects this error and reinstates these new provisions (i.e., obtaining refunds or accessing special tax benefits or regimes through abuse or simulation).
- The delay in the legislative process of the Tax Compliance Law resulted in errors in the time frames provided for certain transitional rules, which ended up being too short or unfeasible. The Short Law extends these deadlines:
a. Until December 31st, 2024, to opt for the extraordinary and voluntary system of declaring assets and income abroad (transitional Article 11);
b. Until December 31st, 2024, to opt for early termination of tax cases initiated before January 1st, 2024, with remission of interest and fines (transitional Article 12); and
c. Up to 90 days from the publication of the Short Law to enter into agreements with the Treasury for the payment of outstanding taxes or administrative fines in up to 48 monthly installments with remission of fines and interest (transitional Article 13).
- The start date of the exemption from customs duties for imports up to US$500 is corrected, so it will take effect in November 2025, together with the elimination of the VAT exemption for imports under US$41. Thus, starting in November 2025, all imports under US$500 will be subject to VAT but exempt from customs duty.
