
The Council of Ministers of Cuba published this Friday the , a regulation that expands the range of commercial activities that foreign branches established in the national territory can undertake, modifying the regulations in effect since 2021.
The order, signed by Prime Minister Manuel Marrero Cruz on September 21, was published in the , on pages four to six, along with four other regulations that together reshape the legal framework for foreign trade representations in Cuba.
The decree amends articles 24, 27, and 29 of Decree 32 of February 22, 2021, which establishes the "Regulations for the establishment of foreign commercial representations in Cuba."
The central change is in Article 27: branches are authorized to import and export directly for commercial purposes, conduct wholesale trade, issue commercial invoices, and distribute and transport goods within the country—operations that had previously been prohibited to them.
The only activity that remains beyond their reach is general retail. The text of the decree specifies this as follows: "Branches may carry out the activities described in the previous section, except for the retail trade described in subsection b)."
The representative offices, on the other hand, maintain the previous restrictions: they cannot import or export directly for commercial purposes, operate in general wholesale or retail trade, issue commercial invoices—except for those under the customs deposit regime—or distribute or transport goods.
The decree also updates the grounds for the cancellation of licenses. The new Article 24 incorporates that the license is extinguished when "the commercial company is in the process of dissolution, liquidation, or has been extinguished," meaning when the parent company ceases to exist.
Additionally, the amended article 29 establishes a 10-business-day period to appeal against cancellation resolutions, which the competent authority must resolve within 30 business days. No further administrative appeal can be made against that resolution, leaving only the judicial route open.
A transitional provision allows representative offices and branches that wish to engage in retail trade or investments to become wholly foreign-owned enterprises under the Foreign Investment Law, with an expedited process for applications submitted within three months following the decree's entry into force.
In the same Gazette No. 82, the was published, signed by Minister Óscar Pérez-Oliva Fraga on September 23.
This resolution regulates the importation of goods for non-commercial purposes by foreign representations and repeals the previous Resolution 73 from April 2021.
Among the goods that representations are authorized to import without a commercial character are furniture and equipment for their offices, construction and electrical materials for maintenance, supplies and professional tools, spare parts for equipment and vehicles, promotional items, and commercial samples.
To carry out those imports, the representatives must submit to the General Customs of the Republic a sworn declaration signed by their highest authority in Cuba and pay the corresponding customs duties.
Both regulations are framed within the package of 176 economic and social transformations presented by Marrero Cruz to the National Assembly in June 2026, described by the regime itself as the largest attempt at structural reform since the Special Period.
The decree itself, 183, cites this framework as justification: “As a result of the approved Economic and Social Transformations, it is necessary to broaden the scope of activities to be carried out by branches established in the national territory.”
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