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Argentina: Draft guidance on transfer pricing compliance procedures

Argentina: Transfer pricing compliance procedures

The Argentine tax authorities (AFIP) posted on the AFIP website a draft of a resolution concerning transfer pricing compliance procedures.


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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:

  • All information that previously was to be submitted in the various transfer pricing returns would be collected and submitted in one form (Form F. 2668).
  • Master file filing obligation would apply for taxpayers with transactions with related parties in an amount exceeding AR$ 500 million (approximately U.S. $8.64 million).
  • Terms are defined and clarifications are included about the features of the transfer pricing analysis that is to be prepared and submitted when an intermediary participates in related-party import or export transactions.
  • While a domestic or local tested party would still be preferred, foreign parties could be allowed to be tested parties according to the methodology, provided that the local taxpayer supplies additional information about the foreign tested party.
  • There are rules concerning business restructuring.
  • Use of reference prices (such as CUP) would apply for certain types of transactions (in particular for the oil and gas industry).
  • The use of local financial information in the transfer pricing analyses would need to be in line with regulations issued by the Argentine Federation of Accountants.
  • Although the present deadline extension would be maintained up to December 2019, for taxpayers with fiscal year-ends during the period from December 2018 to May 2019, the future deadlines for transfer pricing compliance would be established to be the sixth month after the fiscal year-end.

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 |

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