Amendment of Criteria for Issuing "A" Invoices in Argentina

Daniela Lavin
12 minutes ago
2 min read

On June 27, 2025, General Resolution 5716/2025 issued by the Tax Collection and Customs Control Agency (ARCA) comes into force. This resolution significantly modifies the authorization regime for issuing “A” invoices, “A with legend” invoices, and “M” invoices, with direct implications for VAT and Income Tax.

This new regulation replaces the long-standing General Resolution No. 1575 and redefines the technical, financial, and fiscal parameters under which taxpayers are allowed to issue these types of invoices.

What changes under the new resolution?

Automatic quarterly evaluation

From now on, ARCA will evaluate taxpayers every four months (in February, June, and October) to determine whether they are authorized to issue “A” invoices, “A with the legend ‘Transaction Subject to Withholding’”, or “M” invoices. This evaluation will be based on:

Data from the Digital VAT Ledger (Libro IVA Digital) or Form F.2051
Formal compliance with tax obligations
Tax behavior and history
Declared assets (Personal Assets Tax)

Preventive simulation

During the first 7 days of each evaluation month, a preventive simulation will be conducted, notifying taxpayers of any inconsistencies detected. This gives them time to correct issues before the final evaluation, improving transparency and encouraging voluntary compliance.

New asset requirements

To qualify for “A” invoices, the taxpayer must:

Declare assets located in Argentina (excluding cash and household items) worth more than 15% of the non-taxable minimum set by the Personal Assets Tax.
Own real estate and vehicles valued above 6% of that same non-taxable threshold.

Additionally, taxpayers who requested deregistration from VAT within the last 12 months, but were ineligible or issued “M” invoices, are explicitly excluded.

What if the requirements are not met?

The taxpayer will be authorized to issue “M” invoices, but can submit a formal objection via the "Digital Submissions" platform.
Alternatively, taxpayers who do not meet the asset criteria but have no fiscal inconsistencies may choose to issue “A” invoices with the legend “Transaction Subject to Withholding”.

How are the results communicated?

The outcome of each evaluation will be notified via the taxpayer’s electronic tax domicile and made available through the “Invoicing” microsite on ARCA’s official website.

Taxpayers will be able to review the specific inconsistencies or noncompliance through the “Invoicing and Registration Regimes (REAR/RECE/RFI)” service.

Key implications

Greater transparency: Taxpayers can anticipate their status and correct it proactively
Automated, recurring evaluations: Replaces static assessments with ongoing monitoring
Clear asset thresholds: Raise the bar for issuing “A” invoices
Enhanced use of digital tools: Including the Digital VAT Ledger, Form F.2051, electronic notifications, and preventive simulations.