The Argentine tax authorities (AFIP) posted on the AFIP website a draft of a resolution concerning transfer pricing compliance procedures.
The draft resolution relates to certain detailed transfer pricing compliance rules that were expected because of changes introduced to the transfer pricing rules in Argentina by Law N° 27.430 and by Decree N° 1.170. Currently, transfer pricing filing deadlines beginning from fiscal years ending on or after December 2018 had been postponed pending the expected guidance that has now been included in the draft resolution. Read TaxNewsFlash
Among other items, the draft resolution proposes the following guidance:
KPMG observation
Tax professionals have observed that the draft regulation appears to capture most of the pending features about the transfer pricing compliance rules; however, it has been noted that certain terms appear to require some refinement to provide better clarification to taxpayers and practitioners in the application of the rules.
For more information, contact a tax professional with KPMG’s Global Transfer Pricing Services practice in Argentina:
Marcelo Castillo | +54 11 431 65 891 | macastillo@kpmg.com.ar
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