On July 2019, the National Constituent Assembly ("ANC") approved the "Constitutional Law that created the high net worth tax" ("Law"). The Law created a tax of 0,25% ("Tax") on all assets of individuals and legal entities that the National Integrated Service of Customs and Tax Administration ("Service") has designated as special taxpayers ("Special Taxpayers").
On August 16, 2019, the ANC, through an Official Notice, ordered the reprint of the Law in the Official Gazette due to a "material error" of the Law (the ''Notice''). The Notice intends to apply the law retroactively for the fiscal year that started on October 1, 2018 and will close September 30, 3019, even though by the beginning of that fiscal year the Law was not in force.
The Service issued Administrative Guideline No. SNAT/2019/00213, related to the "Rules regarding the value update of assets and the requirements and formalities for the filling and payment of the tax" ("Administrative Guidelines"). The Administrative Guidelines also intend to apply the Tax retroactively.