The foreign exchange market has been experiencing turbulent times in recent months, caused by a problem that the country has been suffering from for many years: the lack of dollar reserves at the Central Bank of the Argentine Republic (BCRA).
Let us remember the soybean dollar with a novel asymmetric devaluation for soybean exporters who brought in fresh dollars from abroad, during the month of September, which allowed the entry of USD 8135, meaning a relief for the exhausted reserves of the Institution located at Reconquista 266, City of Buenos Aires.
Then, the Qatar tourist dollar and the Coldplay dollar emerged to pay for travel and tourism, credit card consumption, shows by non-residents in the country and certain luxury goods. The tax burden on the official dollar is 100% (Country tax 30% + 45% Income tax withholding + 25% Personal Property tax withholding). This measure has caused a significant drop in reservations for tickets abroad, taking into account that the official dollar has been devaluing at a daily rate that almost equals the average monthly inflation of 7% in recent months.
Finally, on October 17, the new import payment regime was implemented simultaneously between the BCRA and the AFIP, through Communication "A" 7622 and Joint Resolution No. 5271/2022, respectively.
Thus, a new Import System of the Argentine Republic called "SIRA" is established, which replaces the previous SIMI.
The characteristics of SIRA are as follows:
- It will be valid for 90 calendar days, counting from the date on which it has the status of “Departure”. The SIRA will contain, from the moment it is registered, the indication of the agencies that must intervene in the import process. In case of extension, it will be for another period of 90 days.
- Once the data requested by the system has been entered, the risk profile and the economic and financial capacity of the CEF importer will be verified for the operation that aims to address formal non-compliance with tax obligations with AFIP.
- By consulting third-party interventions, the MOA will be able to determine the reasons why the application is not allowed to proceed.
- Preliminary checks prior to official declaration:
- The situation of the subject based on the information available in his records
- The risk profile
- The financial economic capacity of the importer to carry out the CEF operation
Single Foreign Trade Current Account
- In addition, the system for consulting and recording foreign exchange operations called “Single Foreign Trade Current Account” was created, in which banks authorized to operate in the Free Exchange Market by the BCRA must consult and record the total amount in pesos of each of the foreign exchange operations at the time they are carried out. For these purposes, they must access the service called “Single Foreign Trade Current Account” through the website (http://www.afip.gob.ar).
- The Single Foreign Trade Current Account covers sales of foreign currency - foreign currency or banknotes - to cancel transactions that have been previously registered through a SIRA/SIMI and are in the OUTPUT status, SIRASE in the APPROVED status, official import dispatches and entry destinations to the Free Trade Zone (ZFI).
- Payments for imports of goods in advance, at sight, deferred without clearance.
- It may also be withdrawn when payment is made through an exchange and/or arbitration against a local foreign currency account of the client and the SIRA declaration states that such option would be used.
- That is, you can pay in advance, at sight, or deferred without dispatch, but with your own dollars stored in the dollar demand account. Keep in mind that you cannot access the exchange market for 90 days before or 90 days after having made the MEP or CCL dollar and other conditions of COM A 7552. There are no more advance, sight or deferred payments without dispatch with SIRA as there were with SIMI except for the exceptions provided for in the rule.
- Luxury goods payable in 180 or 365 days from delivery to the market will have to continue to be paid for in those terms even with local dollars.
- To pay with your own dollars, these must be previously declared.
Payments for imports of goods. Exceptions with SIRA (point 8 of Communication "A" 7622)
- COVID-related assets.
- Pharmaceutical products and/or supplies for medicines.
- The goods paid correspond to the tariff items of petroleum oils or bituminous minerals.
- Unagglomerated bituminous coal produced by a power generation plant.
- Goods with certain tariff items and others intended for the local production of goods necessary for the construction of infrastructure works contracted by the public sector.
- Capital goods with a minimum of 90% BK on the commercial invoice.
Payments for imports of goods with SIRA or clearance from SIRA
- For all payments with delivery to the square from SIRA or with SIRA, they must be validated in the web service controls of both the BCRA and the AFIP Single Foreign Trade Current Account implemented.
- There is no more quota to pay for imports of COM A 7030 BCRA or SIMIS AB or C for operations with SIRA.
- Payments for Letters of Credit with SIRA in the Departure status and the payment will be the date of dispatch plus the term declared in SIRA plus 15 calendar days.
- Financing of imports with foreign funding: The supplier can be paid as long as SIRA is in the output status and the payment to the foreign bank that financed will be the date of dispatch plus the term declared in the SIRA plus 15 calendar days.
- All other regulations regarding payment for goods remain in force.
Payments for services abroad must be made with the authorization of the AFIP called SIRASE - Argentine Republic Services Import System - which replaced SIMPES.
At the time of writing this note, the AFIP Service on line web system had not yet been implemented; therefore, banks are registering payments for imports of goods and services in the Foreign Trade Single Current Account manually. Neither can payments for imports be made by courier or for the exceptions provided for in the regulations, such as capital goods.
Likewise, the Sira are being approved with terms ranging from 210 to 270 days on average to be able to pay abroad. Meanwhile, the delays in the payment of imports (from January to September 2022) are around USD 10.000 billion, taking into account that shipments to the market reached USD 64.000 billion and payments through the foreign exchange market were USD 54.000 billion in the indicated period.
He is a certified public accountant from the University of Buenos Aires (UBA). He has a postgraduate degree in Finance from the Universidad Argentina de Empresas (UADE). Currently, he is Head of the Comex Technical Area at Banco Santander Argentina, since 1987. He also serves as Secretary of the Comex Commission at the Association of Argentine Banks (ABA), since 2011. He has been married for 34 years to Adriana Barsanti, and has three children aged 33, 31 and 26, all professionals.
