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On March 31, 2026, the Internal Revenue Service issued Resolution NAC-DGERCGC26-00000015 (hereinafter, “Resolution”), which reforms the procedures for the issuance, administration, and utilization of tax credit certificates issued by the Tax Authority.
Key Points
Balances in the Title Value Account Statement
Credit notes will now be reflected as a favorable balance in the “securities account statement.” Their utilization shall be restricted exclusively to the electronic channels provided by the Tax Authority.
Use of Available Balances
Payment Limit (60/40)
Effective April 1, upon filing a tax return, the system will allow taxpayers to offset up to a maximum of 60% of the total amount due—including fines and interest—using available tax credits from the taxpayer’s account statement.
The remaining 40% must be settled through the standard payment methods authorized by the SRI.
This limitation does not apply to tax credits originating from the Currency Outflow Tax (ISD), which maintain their specific and restrictive treatment in accordance with current regulations.
Impact on Customs Operations
The new resolution repeals Article 10 of Resolution NAC-DGERCGC21-00000051, thereby removing the faculty of taxpayers to guarantee the fulfillment of customs obligations through the use of SRI tax credit certificates.
Entry into Force and Application
The Resolution becomes effective on April 1, 2026. However, the amendment introducing the use of the statement of account as a negotiable instrument for the management and application of dematerialized credit notes in the settlement of tax obligations shall be applicable as of May 1, 2026.
Anticipation is key. Our team is ready to assist you in assessing the impact of this resolution on your daily operations.
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This publication contains information of general interest and does not constitute legal opinion on specific issues. Any analysis will require legal advice from the Firm.