On January 16, 2026, the Federal Tax Authority (ARCA) published General Resolution 5815/26 on the Official Gazette, thus establishing an advanced payment on Income Tax applicable to the definitive export of gold, silver, and platinum —including doré bullion— in cases where no transfer of ownership occurs. This new regulation specifically applies to exports for metal refining or storage, led by their subsequent sale.
The advanced payment amounts to 1% of the export value declared on the ES03 export declaration. The exporter must assess and pay the resulting amount within 15 business days following export clearance. Failure to meet this deadline will not only accrue compensatory interest but may also result in the exporter's temporary suspension from the importers/exporters registries until the obligation is settled.
Additionally, the regulation establishes a quarterly information regime for those exporters subject to this advanced payment. They must submit, via the "Digital Presentations" service, a certification issued by an independent professional verifying the quantity and quality of the exported metals, linking them to their respective export declarations.
The regulation comes into effect on January 17, 2026.
