LEGAL ALERT | TAX
Cochabamba, September 2026
I. Background
Tax Relief Law No. 1733 of 27 May 2026 established, in Article 3, Paragraph I, an exceptional tax debt regularisation regime for a period of one hundred and twenty (120) calendar days, which expired on 23 September 2026. The same provision authorised the Executive Branch to extend that period until 31 December 2026.
II. Content of the decree
Under that authority, Supreme Decree No. 5708 was enacted on 16 September 2026, extending the deadline until 31 December 2026 for taxpayers subject to the National Tax Service (SIN) and National Customs to regularise their tax position under the same conditions established by Law No. 1733.
The Decree does not amend the tax periods covered, payment arrangements or benefits provided by the Law.
III. Scope of the regularisation regime
a) Periods covered
Tax debts relating to tax periods between 1 January 2018 and 31 December 2025. Obligations relating to the 2026 fiscal year are not covered.
b) Payment arrangements and benefits
1. Payment in full: the taxpayer pays the outstanding tax, adjusted with fifty per cent (50%) of the inflation adjustment. The remaining inflation adjustment, interest and penalties for failure to pay, tax or customs fraud and breaches of formal obligations relating to the tax being regularised are waived.
2. Payment plans of up to thirty-six (36) monthly instalments: the outstanding tax is adjusted as of the publication date of Law No. 1733, without a discount on the inflation adjustment, and the aforementioned interest and penalties are waived. Under Article 3, Paragraph VII of the Law, default under the plan results in the loss of benefits and recalculation of the debt pursuant to Article 47 of the Bolivian Tax Code.
c) Eligible taxpayers
Eligible taxpayers include, among others, those who:
• have filed tax returns but have not paid the tax due;
• have not filed their tax returns, or have filed returns containing incorrect information, and subsequently file or amend them;
• are subject to audit, verification or control proceedings, or have been served with a preliminary tax assessment, a tax assessment resolution or a tax enforcement instrument;
• have current or defaulted payment plans, in respect of outstanding balances;
• are pursuing administrative or judicial challenges, subject to full or partial withdrawal (Article 3, Paragraph III);
• are subject to tax enforcement or compulsory collection proceedings, provided that the adjudication of assets has not taken place (Article 3, Paragraph IV).
IV. Key considerations
1. No further extension by regulation. The latest deadline authorised by Law No. 1733 for the Executive Branch is 31 December 2026. Any further extension would require a new law.
2. Subsequent audit powers. Under Article 3, Paragraph II, the Tax Administration retains the authority to audit taxpayers who regularise their position by filing or amending tax returns. Any differences assessed must be paid in accordance with the Tax Code, without the benefits of the Law.
3. Inflation adjustment. Under the payment-in-full option, outstanding tax continues to be adjusted using the UFV until the payment date.
4. Withdrawal of ongoing challenges. Regularising disputed debts requires withdrawal of the appeal. This decision should be assessed on a case-by-case basis, taking into account the taxpayer’s legal position in the proceedings.
V. Recommendations
We recommend that our clients:
• identify outstanding obligations for the 2018–2025 periods with the SIN and National Customs;
• determine which provision of Article 3 of Law No. 1733 applies to each obligation;
• compare the effective cost of payment in full against instalment plans;
• assess whether withdrawing ongoing challenges is appropriate;
• begin the process well in advance, considering the year-end period and potential congestion on the platforms in December.
VI. How can we assist you?
Reinicke Ostria can advise on the assessment of your tax position, calculation of your obligations, your strategy for entering the regime and follow-up of the process before the National Tax Service and National Customs. Please contact us for further information.
Legal references: Tax Relief Law No. 1733 of 27 May 2026 (Article 3); Supreme Decree No. 5708 of 16 September 2026; Law No. 2492, Bolivian Tax Code (Article 47).
This alert is for information purposes only and does not constitute legal advice. For advice on specific cases, we recommend consulting a professional.