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Argentina: Delayed effective date, transfer pricing compliance rules

Argentina: Transfer pricing compliance rules

The Argentine tax authorities (AFIP) today released for publication in the official bulletin a general resolution concerning the effective date of certain transfer pricing compliance rules.


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Today’s release—Resolución General 4650/2019 (Spanish)—delays compliance deadlines as provided in a prior resolution, Resolución General 4538/2019 [PDF 123 KB] (Spanish).

In general, these transfer pricing compliance rules would implement changes introduced to the transfer pricing rules by Law N° 27.430 and by Decree N° 1.170 (December 2018). Transfer pricing filing deadlines measured as from fiscal years ending on or after December 2018, however, had previously been postponed pending guidance provided by a draft resolution (October 2019). Read TaxNewsFlash

KPMG observation

There are reports that delayed implementation of these transfer pricing rules is to allow officials of the new government (elected in October 2019) more time to review the draft resolution before it is released.


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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