Overview

• Published Sept. 5 in RG 5753/2025, the change enables compensation only when the credit holder and the liable taxpayer are the same person and the balances are liquid and enforceable.
• Requests must be filed through the Sistema de Cuentas Tributarias with real‑time validations, and inconsistencies can be resolved by submitting documentation via Presentaciones Digitales.
• Eligible credits include those from determinations, original or rectificative returns, or firm administrative or judicial rulings, and the update replaces RG 1658 and removes limits set by RG 1.658, 3.175, 4.334 and 4.521.
• Applicable credits prescribe after five years, offsets take effect upon submission if requirements are met, and unused validated balances can be applied to later periods.
• As part of the same reform drive, RG 5752/2025 effective Sept. 1 scrapped the decade‑old regime forcing reports on operations with foreign representatives, with ARCA maintaining audits through simpler tools and keeping transfer‑reporting thresholds at ARS 50 million for individuals and ARS 30 million for legal entities.