The Servicio de Impuestos Nacionales (SIN), Bolivia’s tax authority, has a peculiar way of changing its mind. In April 2024 it cut the maximum term of payment facilities from 60 to 30 months, under Supreme Decree 5145. In April 2025 it entrenched that limit in a new regulation, RND 102500000019. And on 1 September 2026, with a single article that replaces the word “thirty” with “sixty”, it put the term back where it started. RND 102600000033 implements Supreme Decree 5687 of 31 August, which in turn amended Article 24 of SD 27310, the regulation to the Bolivian Tax Code. Anyone with an outstanding tax debt to the central administration may now ask to pay it over up to five years.
The change is small in its text and considerable in its effect. A debt that previously had to be spread over at most 30 instalments can now be spread over 60, with a monthly instalment roughly halved. And it arrives as part of a sequence. In June, RND 102600000020 had set the initial payment and the guarantee at a flat 5%, removing the sliding scales that reached 15% and 20% for larger debts. In three months the SIN has lowered the entry cost, the guarantee and now the term. It does so in the same month the government publishes a memorandum with the IMF announcing a strategy to raise revenue. There is no contradiction. A payment facility forgives nothing; it turns a debt that might never be collected into one collected over five years, with interest and against a guarantee.
What the rule says and with what rank
The resolution is a general administrative rule issued under Article 64 of the Tax Code, which empowers the SIN to regulate without altering the tax or its elements. It binds the administration and the taxpayers under its jurisdiction, meaning national tax debts, not municipal or customs debts, which have rules of their own. The underlying power sits in the statute, not in the resolution. Article 55 of the Tax Code allows payment facilities to be granted “once only and without extension”, at the taxpayer’s express request and at any time, including after tax enforcement has begun. The term is set by the Code’s regulation, SD 27310, whose Article 24 now reads 60 months. The RND simply aligns its own Article 5 with that decree.
For the Treasury it is a bet on collecting more slowly but collecting; for the taxpayer, a window that can be crossed only once.
Everything else is unchanged. The application is filed through SIAT en Línea, the initial payment and the guarantee have been 5% since June, the monthly instalment may not fall below 200 UFV once both are deducted, and instalments run from the first business day of the month following notification of the Administrative Resolution that authorises the facility. One point of reading: the decree says “the first day of the following month” while the resolution keeps “the first business day”. In practice the resolution governs, since it is what the system applies, but the difference exists and is worth keeping in mind if a due date is ever disputed.
What changes for those who already owe, and those who already have a facility
The extension reschedules nothing of its own motion. Anyone with a facility in force at 30 months keeps it on its terms, and the rule makes no provision for extending it. Here Article 55 weighs. A facility is granted once per debt and cannot be extended, so a taxpayer who obtained one at 30 months cannot now request a second at 60 on the same obligation. The novelty favours those who have not yet applied, or who have new debts or debts distinct from those already covered. For a taxpayer deciding whether to apply, the arithmetic also shifts. With the minimum instalment at 200 UFV, a modest debt over 60 months may produce instalments below the floor, in which case the system will shorten the term; the real benefit of five years lies in medium and large debts.
Default has the effect it always had. The facility lapses and the balance goes, or returns, to tax enforcement, with the guarantee enforceable. Lengthening the term lowers the instalment, but it also lengthens the period during which a company lives with a guarantee posted in favour of the Treasury and with an obligation on which interest keeps accruing until payment. Over five years, the financial cost of the facility deserves comparison with that of a bank loan, particularly when the memorandum with the IMF anticipates higher interest rates and the end of rate caps in June 2027.
The context
The 2024 to 2026 sequence says more than any single rule. The cut to 30 months in April 2024 came when the Treasury most needed immediate cash; the return to 60 comes when the stated aim is to “ease compliance” for firms under liquidity strain, in the second year of recession. By regional standards the Bolivian term is generous. The special regime Argentina’s tax agency opened this year for debts overdue at 30 June 2026 allows up to 18 instalments for small firms and 15 for mid-sized ones, with a down payment of 5% to 10%; the Chilean Treasury’s ordinary agreements run to 24 instalments with a deposit of between 10% and 30%. Sixty months with 5% down is, in that company, the widest door.
What to do
- Take stock of outstanding tax debts, including those already under enforcement, and separate those that have never had a facility from those that have. Only the former qualify for the new term.
- Run the 60-month facility through the SIAT calculator before applying, checking that the instalment exceeds 200 UFV and comparing the total cost with bank financing.
- Budget for the 5% initial payment and guarantee in cash or securities, or the first-demand bank guarantee, which must remain in force for the whole term.
- If a facility is already in force, do not assume it can be extended; review with counsel whether to see it through or whether the debt admits another treatment.
- Align the instalment calendar with the rest of the adjustment ahead, in particular fuel prices from January 2027, so as not to stack due dates in the same quarter.
The resolution’s single article fits on one line. Its consequences do not. For the Treasury it is a bet on collecting more slowly but collecting; for the taxpayer, a window that did not exist in 2025 and which, by the Code’s design, can be crossed only once.
