Bolivia’s Tax Authority Allows Withheld Funds to Be Used for Tax Payment Plans
RND No. 102600000022 allows taxpayers subject to fund withholding measures to use withheld amounts as the initial payment and/or cash guarantee required to access tax payment facilities.
Bolivia’s National Tax Service (SIN) issued Regulatory Board Resolution No. 102600000022, dated 29 June 2026, amending RND No. 102500000019, which governs the requirements, methods, deadlines and procedures for requesting, granting, monitoring and controlling tax payment facilities.
The amendment is short, but practically significant. In a context of economic pressure and liquidity constraints for many companies and taxpayers, the rule allows taxpayers subject to the coercive measure of fund withholding to use the withheld amounts to cover the initial payment and/or cash guarantee required to access a payment facility.
From a practical standpoint, the measure addresses a common tax enforcement dilemma: taxpayers may be willing to regularise their obligations, but the funds they need are immobilised by the Tax Administration itself. The new rule allows those funds to be used to open an orderly payment path.
A narrow amendment with real-world consequences
The Resolution is grounded in the Tax Administration’s authority to grant payment facilities, including after tax enforcement has already begun. The Bolivian Tax Code authorises the Administration to grant such facilities upon the taxpayer’s express request, and the implementing regulations allow complementary rules on their application.
The change introduced by RND No. 102600000022 consists of adding a new paragraph to Article 6 of the Payment Facilities Regulation.
As a result, taxpayers subject to a Fund Withholding measure may use the retained amounts for:
- the Initial Payment of the payment facility;
- the Cash Guarantee; or
- both, as applicable.
The rule does not cancel the tax debt or waive accessories. Nor does it automatically lift the coercive measure. Its importance lies elsewhere: it allows resources already immobilised to be used to make a payment plan viable.
Applicable procedure
The procedure is straightforward.
The taxpayer must file a written request with the relevant District Office or GRACO Office of the SIN.
The Tax Administration must accept or reject the request within two business days. If accepted, the responsible public officer must request, on the same day, the payment facility number obtained by the taxpayer through the Virtual Tax Office. The officer must then allocate the initial payment and/or cash guarantee within a maximum period of three business days.
If the request is rejected, the District Office or GRACO Office must issue a reasoned response. This is relevant because it allows the taxpayer to understand the grounds for rejection and evaluate next steps.
Why it matters for companies and taxpayers
The amendment should be read against the backdrop of Bolivia’s economic pressures and the policy goal of encouraging voluntary compliance. The Resolution itself refers to the economic crisis affecting taxpayers’ ability to comply with tax obligations on time, and justifies the adjustment on grounds of reasonableness, proportionality and promotion of voluntary compliance.
For companies facing tax debts under enforcement, fund withholding can become a serious constraint: it affects liquidity, disrupts operational payments and limits the ability to negotiate or comply with a regularisation plan. The new rule does not remove that tension, but it creates a more functional exit route.
In practice, the rule may be useful for taxpayers that:
- have bank accounts affected by fund withholding measures;
- need to access a tax payment facility;
- lack additional liquidity to cover the initial payment;
- must provide a cash guarantee;
- seek to regularise their tax exposure without waiting for enforcement to run its course;
- are evaluating payment alternatives before the SIN.
The rule may also reduce administrative friction. By establishing short response and allocation deadlines, it creates a clearer expectation regarding the SIN’s processing of these requests.
Legal and strategic reading
Although the amendment is procedural, its significance is broader. In tax matters, the effectiveness of a payment plan regime depends not only on the taxpayer’s willingness to comply, but also on the actual availability of resources to meet the initial conditions.
If the taxpayer’s funds are already withheld, requiring an initial payment from different resources may make regularisation impractical. The Resolution partially corrects that problem by allowing funds already under the Tax Administration’s control to be used to activate the payment facility.
From a legal perspective, the measure also reinforces the importance of proper documentation. The request, acceptance or rejection, payment facility number, allocation of amounts and applicable deadlines should all be carefully monitored.
Practical recommendations
Taxpayers with withheld funds and outstanding tax debts should consider:
- identifying whether a Fund Withholding measure is currently in force;
- verifying the retained amount and the financial institution involved;
- assessing whether the debt is eligible for a payment facility;
- preparing the request to the relevant District or GRACO Office;
- obtaining the payment facility number through the Virtual Tax Office;
- monitoring the two-business-day deadline for acceptance or rejection;
- monitoring the three-business-day maximum period for allocation;
- keeping documentary evidence of the entire process;
- reviewing how the payment facility may affect other enforcement measures or pending proceedings.
Conclusion
RND No. 102600000022 is not a large-scale tax reform. It is, however, a useful tool for taxpayers with withheld funds and outstanding tax debts.
Its importance lies in turning immobilised funds into a mechanism to access tax payment facilities. In an environment of tighter liquidity and greater fiscal pressure, that flexibility may be the difference between a debt under enforcement and a viable regularisation path.
For companies, the message is practical: review existing coercive measures, assess whether withheld funds can be used, and act promptly to take advantage of the procedure established by the Resolution.
