A mining company shipping concentrates abroad, or a crusher exporting soybean meal and oil, pays value added tax (IVA) on much of what it buys in Bolivia, from diesel to spare parts and services. Because its export sales are relieved of output tax, that IVA turns into a credit which, for a company with few domestic sales, has little to offset it against. Law No. 843 (art. 11) and Law No. 1489 (art. 12) deal with the problem through the principle of tax neutrality, under which domestic taxes and duties built into the cost of exported goods are refunded. The refund takes the form of a Tax Refund Certificate, known as the CEDEIM.
A CEDEIM is not cash but a negotiable instrument. It can be used to pay any tax owed to the National Tax Service (SIN) or the National Customs Service, and because it is transferable, a company without enough tax to pay can endorse it to one that has, usually at a discount. COMIBOL, the state mining company, adopted an internal rulebook in 2016 for selling its certificates to banks through a public call, with the discount fee borne by COMIBOL. For sectors that export heavily and buy heavily at home, the certificate is part of working capital and every delay has a financing cost. In 2022 the government’s economic policy unit, UDAPE, citing the Ministry of Mining, recorded average refund delays of one and a half to two years for mining companies. When the previous administration adjusted the 15-day CEDEIM track in 2024, open to exporters who posted a guarantee and showed foreign-currency inflows, it set specific thresholds for agribusiness (73% of export value) and for mining and metallurgy (70%), against 60% for everyone else (Supreme Decree No. 5227). And in late 2025 the oilseed industry chamber (CANIOB) and the Santa Cruz exporters’ chamber (CADEX) set up a working group with the Ministry of Economy and the SIN to unblock the process.
Supreme Decree No. 5748, signed on 13 October and in force from 1 June 2027, promises to bring order to that process. Its central bet is plain on a first reading. Instead of treating every refund claim alike, the SIN will rate each purchase invoice by risk and fast-track the clean ones. The practical consequence is less obvious. How quickly an exporter recovers its IVA will depend on the tax behaviour of its suppliers, while the final step, the issue of the certificate, remains tied to the budget set by the Ministry of Economy and Public Finance, with no deadline attached.
A certificate that lives in a register
The first change concerns form. The CEDEIM becomes digital, or “dematerialised” (art. 2). It remains a transferable fiscal instrument of indefinite validity, as it has been since Supreme Decree No. 25465 of 1999, but acts relating to it will carry a digital signature and its legal validity and evidentiary weight will rest on a register of ownership. The SIN must issue rules on transfer, endorsement and splitting. Paper certificates already issued remain valid and may be converted to digital form at the holder’s request. For buyers in the secondary market, a single register should reduce the risk of doubtful endorsement chains; by how much will depend on the implementing rules.
Three channels for every invoice
The substantive change sits in articles 7 to 11. The SIN will run a Risk Management Model built on statistics, algorithms and business intelligence, whose criteria, weightings and thresholds an internal committee will approve and update every year. Before claiming a refund, the exporter uploads its purchase invoices to the SIN’s system, which rates them within 10 days and notifies the result through the Tax Mailbox (Buzón Tributario). Each invoice lands in one of three channels.
The light-blue channel, for low risk, covers electronic invoices from suppliers with no tax-risk flags, a sound compliance record and evidence that payment went through the financial system; its review is automated. The purple channel, for medium risk, takes manual invoices and electronic ones showing signs of being simulated or sham, a lack of commercial logic for the exporter’s business or links or history that warrant checking, and allows site visits only when the paperwork is not enough to form a view. The red channel is reserved for sham, simulated or non-existent transactions, or those backed by documents at high risk of falsity, and adds data-intelligence analysis and, where necessary, a visit.
Deadlines follow the channel. In light blue, the SIN has 5 days to review the claim and issue a resolution accepting it. In purple, it has 5 days to serve a review order and 45 to carry out the review; if it raises objections, the exporter has 10 days to respond, extendable at its request to 30, and the SIN another 10 to decide. In red, the review runs to 90 days. In both reviewed channels, deadlines may be suspended once, by reasoned resolution and for up to 30 days, if the SIN asks the exporter, third parties or Customs for more information. By our count, taking every step at its longest and leaving suspension aside, the purple channel can reach 90 days and the red channel 135, adding the days as the decree states them. One technical point. With two exceptions, the decree speaks of “days” without saying whether they are business or calendar days. Until the SIN clarifies, the likeliest reference is the Tax Code, which counts periods of up to ten days as business days and longer ones as calendar days (art. 4).
Invoices from the same export may fall into different channels, and the decree allows a claim to be filed with invoices of all three colours “concurrently or separately” (art. 10.II). In practice, a company could obtain a ruling on the light-blue share of its credit within days and wait weeks or months for a ruling on the rest, although in both cases the certificate itself will still depend on the budget. The filing window is essentially unchanged at 180 days from the first business day after the export period, and late claims get no refund.
Three routes and a guarantee for 100% of the VAT and excise tax
The channel also decides how the refund is delivered (art. 3). Light-blue invoices go through the expedited route, with no guarantee. Purple and red ones can take the regular route, also without a guarantee but after the Tax Refund Review (CDI), or the immediate route, under which the CEDEIM is issued against an on-demand bank guarantee or surety bond for 100% of the IVA and excise tax (ICE) claimed, and remains subject to review. The guarantee must be irrevocable, unconditional and enforceable on demand, and run for at least 140 days from the certificate’s issue in the purple channel and 180 in the red, with mandatory renewal if the review overruns or the exporter appeals. Once a resolution rejecting all or part of the claim becomes final, the company has 3 days to repay the difference with interest and inflation adjustment; if it does not, the SIN calls the whole guarantee, keeps what it is owed and returns the balance in tax credit notes (CENOCREF).
The budget, the one variable without a deadline
This is the decree’s central tension. Except on the immediate route, all the deadlines above lead to an administrative resolution, and the certificate comes later. Under article 5, once the resolution accepting the claim becomes final, the amount “will be included in the schedule for issuing the CEDEIM”, with no time limit. That schedule depends on the budget allocated by the Ministry of Economy and Public Finance, which article 4 splits into three slices, each served in chronological order. Half goes to the expedited route and to refunds ordered by final administrative or court rulings, 30% to the regular route and 20% to the immediate one. Unused balances may be reallocated under administrative rules.
Two details deserve attention. Light-blue exporters share their 50% slice with companies that win refund litigation, so a year with many favourable rulings could lengthen their queue. And the Second Transitional Provision orders certificates pending delivery to be issued out of 50% of the allocated budget until those claims are settled, without explaining how that slice fits with the article 4 split, a relevant question for a system with a backlog. The immediate route carries one more condition. The exporter has 90 calendar days from notice of the budget schedule to post the guarantee, or the claim is treated as withdrawn (art. 12.II).
What the decree repeals and what it leaves open
From 1 June 2027, articles 13 to 17, 20 and 22 of Supreme Decree No. 25465 are repealed. They include article 16, whose paragraph (e), added in 2024 by Supreme Decree No. 5145 and amended by Supreme Decree No. 5227, governs the 15-day CEDEIM track against a guarantee and proof of foreign-currency inflows. The new decree does not mention foreign currency, and exporters should check the SIN’s implementing rules for any surviving foreign-exchange condition on refunds.
The transition also leaves a grey area. Claims pending on the date of publication will follow the rules in force when they were filed (First Transitional Provision), but the decree is silent on claims filed between publication and 1 June 2027 that are still pending on that date, which were not “pending on the date of publication” and will have lost the articles that governed them. Separately, exports under the inward-processing regime (RITEX) are excluded from refunds of customs duty (Sole Additional Provision).
What to do before June 2027
For exporters, the main lesson is that suppliers’ tax compliance becomes a cash-flow variable. A mining company that buys from small contractors issuing manual invoices will see those purchases routed at best to purple, with a procedure that, by our count, can take up to 50 days even without objections and before any suspension, and purchases paid in cash will struggle to meet the light-blue conditions. The same applies to a crusher with a long chain of haulage and storage providers. It is worth checking whether existing supply contracts require electronic invoicing, payment through the financial system and an indemnity if an invoice is later challenged; where they do not, the decree’s entry into force is a natural moment to renegotiate. The register of risk suppliers that the SIN will keep (art. 16), fed by final rulings against buyers who used sham or simulated invoices, should become part of supplier onboarding once the implementing rules clarify who can consult it.
Article 18 adds an internal incentive, since missing or poor accounting records, financial statements and files may count as a risk factor. The immediate route, for its part, calls for arithmetic. A guarantee for 100% of the IVA and ICE, valid for at least 140 or 180 days, has a bank cost that must be weighed against the value of being paid sooner, bearing in mind that this route gets the smallest share of the budget.
For investors and acquirers, the decree offers a new due-diligence lens. The risk profile of an exporter’s invoices, not just the balance of tax credit receivable, will show what that receivable is worth and when it will be collected. And buyers of third-party certificates will have, if the implementing rules deliver what article 2 promises, a register in which to confirm ownership before paying.
The decree brings order to a process that exporters have been asking to speed up for years, and gives it deadlines that depend on the risk of each invoice. Its effectiveness will hinge on three pieces that do not yet exist, the SIN’s implementing rules, the criteria of the risk model and the budget allocation. The decree sets the SIN no deadline for the first two, although without them the system can hardly work on 1 June 2027. The third will be decided every year.
