Tax Bulletin September 2026

I. HIGH IMPACT TAX UPDATES

1. Customs Duty and VAT Exemption for Certain Goods Used in Productive Sectors. Supreme Decree No. 5709, dated September 16, 2026.

Supreme Decree No. 5709 implements Article 9 of Law No. 1755 and sets out the requirements for the five-year exemption from Customs Duty and Value Added Tax (VAT) on imports of certain goods used in the agricultural, industrial, construction, transportation and mining sectors. The exemption applies only to goods falling under the tariff subheadings specifically listed in the Annex to the Supreme Decree. These include certain inputs, seeds, veterinary products, fertilizers, machinery, equipment, tools, freight vehicles and other goods used in the eligible sectors. For domestic transactions, the VAT exemption applies only to the first sale made by the importer. The corresponding invoice, tax document or equivalent must be issued without generating VAT input tax credit for the purchaser. Any subsequent sale is subject to VAT under the general rules. To qualify for the exemption, importers must verify the tariff classification of the goods, confirm that they are included in the Annex and ensure that they are intended for use in one of the eligible sectors. Finally, companies planning imports, investments, acquisitions or sales of these goods during the fourth quarter of 2026, throughout 2027 and in subsequent fiscal years should take into account, as part of their planning, the possibility of the early repeal of this incentive, particularly in light of paragraph 14 of the Memorandum of Economic and Financial Policies associated with the IMF-supported programme, which expressly refers to the repeal of Article 9 of Law No. 1755.

2. Transparent VAT and Adjustments to the Invoicing System. Law No. 1733, dated May 27, 2026, and RND No. 102600000034, dated September 1, 2026.

Law No. 1733 amended Article 5 of Law No. 843 to provide that VAT is not part of the net sales price and must be shown separately on the invoice. To implement this change, the National Tax Service (SIN) is developing adjustments to the Invoicing System, including new tax invoice formats based on the taxpayer’s type of activity and changes to the authorization process for in-house and third-party computerized invoicing systems. Through Board Normative Resolution (RND) No. 102600000034, the SIN released the Technical Annex to Law No. 1733 (version 0.0, still under development) and set a period from October 1 to November 16, 2026, during which taxpayers using in-house or third-party systems must meet its specifications in order to begin testing in the pilot environment and obtain authorization. Until the RND implementing the changes is published and takes effect, RND No. 102100000011 remains in force. Companies should work with their IT teams or system providers to assess whether their systems can be adapted within the set timeframe, and should monitor new versions of the Annex and the implementing Supreme Decree. We note that the Transparent VAT regime is not yet in force, as its implementation remains subject to the National Government issuing the corresponding regulations by Supreme Decree. Nevertheless, the measures currently being undertaken by the Tax Administration are intended to facilitate the progressive adaptation of both the Tax Administration and taxpayers to the invoicing and tax compliance implications arising from the Transparent VAT regime. Against this background, companies should begin preparing for the implementation of Transparent VAT well in advance. This process will necessarily require a coordinated, cross-functional approach involving, among others, the Legal, Tax, Commercial, Marketing, Billing, Finance, IT and Regulatory teams, in order to identify and implement the legal, operational, systems and compliance changes required by the new regime.

3. Extension of the maximum term for Payment Facilities. Supreme Decree No. 5687, dated August 31, 2026, and RND No. 102600000033, dated September 1, 2026.

Supreme Decree No. 5687 extends the maximum term for granting Payment Facilities from thirty (30) to sixty (60) months, allowing tax debts covered by this mechanism to be settled through monthly installments over a maximum period of five (5) years. To implement this amendment, the National Tax Service (SIN) issued RND No. 102600000033, which amended Article 5 of the Payment Facilities Regulations by expressly replacing the maximum term of thirty (30) months with sixty (60) months. The extension provides taxpayers with greater flexibility to structure the settlement of their tax debts and may reduce the amount of the corresponding monthly installments. However, the amendment does not, in itself, result in the automatic rescheduling of previously approved Payment Facilities.

4. Sale of diesel at a Reference Price. Supreme Decree No. 5676, dated August 16, 2026.

Supreme Decree No. 5676 establishes a new framework for the sale of diesel, under which direct customers and large consumers will no longer purchase this fuel at the regulated retail price and will instead purchase it at a Reference Price determined on the basis of import costs, applicable taxes and other components established under the relevant regulations. The main aspects of the regulation include the following:

• Reference Price: As a transitional measure, an initial Reference Price of BOB 18 per liter is established, comprising import costs and the taxes applicable to the sale of diesel, primarily Value Added Tax (IVA) and the Special Tax on Hydrocarbons and Derivatives (IEHD).
• Invoicing: Service stations and fuel outlets must adapt their invoicing systems to apply this new sales framework.
• Price differential: For sales to direct users, the difference between the Reference Price and the regulated wholesale price must be deposited in favor of YPFB, in accordance with the procedures, deadlines and conditions to be established by the state-owned company.
• Customs Duty: In addition, the Supreme Decree provides for a zero percent (0%) Customs Duty (GA) on gasoline for motor vehicles until December 31, 2027.

This measure is particularly relevant for companies with fuel-intensive operations, given its potential impact on operating costs and diesel procurement planning.

5. Memorandum of Economic and Financial Policies. Ministry of Economy and Public Finance. September 2026.

The Memorandum of Economic and Financial Policies sets out a roadmap aimed at strengthening revenue collection and fiscal sustainability throughout the term of the program agreed between the Government and the IMF. From a tax perspective, the Government envisages that any new measure with fiscal implications will be subject to a prior assessment and accompanied by offsetting measures. It also plans to develop, by March 2027, an Internal Revenue Mobilization Strategy comprising specific tax policy measures, revenue administration initiatives, and customs reforms. More significant revenue-side fiscal measures would be implemented gradually during the second and third years of the program. The Memorandum also contemplates potential tax reforms related to the formalization of employment, as well as a review of the tax frameworks applicable to the hydrocarbons and mining sectors. The Memorandum expressly states that the 2027 Budget should consider the repeal of Article 9 of Law No. 1755, which established a five-year exemption from GA and VAT for certain goods intended for productive sectors. Consequently, companies potentially benefiting from this incentive should consider the possibility that it may be effective for a shorter period than originally planned when planning imports, investments, acquisitions and sales.

II. TAX INITIATIVES TO FOLLOW UP AND CONTROL

1. Bill to eliminate the Transaction Tax and promote formalization, investment and employment. Chamber of Deputies. Bill No. 678/2025-2026.

The Bill seeks to eliminate the Transaction Tax (IT) by repealing Articles 72 through 78 of Law No. 843, together with the regulatory and administrative provisions governing its assessment, calculation, filing, withholding, collection and payment. The proposal clarifies that the potential elimination of the IT would not entail the forgiveness, amnesty or remission of pre-existing tax liabilities. Accordingly, taxable events arising before the future law enters into force, as well as outstanding obligations and ongoing proceedings, would remain subject to the legal framework applicable at the time they arose. If enacted, the elimination of the IT would represent a significant change to the Bolivian tax system and could reduce the tax costs associated with transactions currently subject to this tax.

2. Bill for the promotion, protection and facilitation of productive investments. Chamber of Deputies. Bill No. 689/2025-2026.

The Bill proposes establishing a general framework for the promotion, protection and facilitation of domestic and foreign productive investments, incorporating tax stability measures and mechanisms designed to encourage new investment. The proposed mechanisms include accelerated depreciation of productive assets, specific treatment of tax credits or tax refunds during the project installation phase, incentives for the reinvestment of profits, tax deductions related to research and development, and differentiated customs treatment for certain capital goods. The Bill also proposes that tax stability benefits be available only to investments classified as strategic and be established through specific legislation defining the applicable taxes, scope, term and relevant conditions.

III. OTHER TAX NEWS

1. Departmental Law on the regularization of departmental tax debts (Departmental Tax Relief Program). Departmental Law No. 421, dated August 14, 2026.

The Law establishes an exceptional period for the regularization of liabilities related to the Departmental Tax on Gratuitous Transfers of Property and the fees administered by the Autonomous Departmental Government of Santa Cruz. Taxpayers participating in the program may benefit from a one hundred percent (100%) waiver of penalties and interest, provided that the outstanding tax liability is paid in full. The benefit may apply to debts undergoing audit, assessment or tax enforcement proceedings and, where an administrative or judicial challenge is pending, the taxpayer must first formally withdraw such challenge. The deadline to participate in the Departmental Tax Relief Program is September 30, 2026.