RIGI: Modifications and Clarifications Regarding the Issuance of VAT Fiscal Credit Certificates
Tax Law Department Report | RIGI: Modifications and Clarifications Regarding the Issuance of VAT Fiscal Credit Certificates
Through General Resolution 5682/2025, published in the Official Gazette on April 30, 2025, the Revenue and Customs Control Agency (“ARCA”) has introduced a series of adjustments related to the procedure for using VAT Fiscal Credit Certificates by Single Project Vehicles (“VPU”).
The Large Investment Incentive Regime (“RIGI”) established a benefit for VPUs, allowing them to offset Value Added Tax (“VAT”) invoiced to them for the purchase, construction, manufacturing, processing, and final importation of capital goods—among others—through the submission of VAT Fiscal Credit Certificates generated via the web service “CERTIVA – VAT Fiscal Credit Certificates.” This was regulated by General Resolution 5589/2024, which launched the service as of December 1, 2024.
This new ARCA resolution—which amends General Resolution 5589/2024—provides clarifications regarding the issuance of certificates when they are issued by a VPU acting as a substitute taxpayer (pursuant to Section 4, Subsection H of the VAT Law), as well as regarding certificates related to final imports of goods. Additionally, it introduced modifications concerning the manner in which VPUs must report these types of adjustments in their VAT Tax Return.