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Argentina: Transfer pricing compliance rules, reporting dates established

Argentina: Transfer pricing compliance rules

The Argentine tax authorities (AFIP) today released for publication in the official bulletin a general resolution that sets forth rules for compliance with transfer pricing reporting rules and that also establishes the effective date for compliance with these transfer pricing reporting requirements.

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The transfer pricing compliance rules in Argentina are intended to implement changes introduced to the transfer pricing rules by Law N° 27.430 and by Decree N° 1.170 (December 2018). Final implementation of the transfer pricing rules, however, was postponed by a number of prior resolutions.

Resolución General 4717/2020 (Spanish) reflects measures that were proposed in an October 2019 draft resolution (read TaxNewsFlash), but also provides more detailed guidance as the final version of the transfer pricing compliance rules in Argentina.

In brief, changes in the general resolution reflect the following:

  • All information that previously was to be submitted in the various transfer pricing returns will be collected and submitted in one form (Form F. 2668) that also will include information from Form 4,501 concerning the transfer pricing report and the CPA certification.
  • The Master file requirement is confirmed, and will apply for taxpayers that belong to a multinational entity (MNE) group with revenues above AR$ 2,000 million (approximately U.S. $29.5 million) and/or intercompany transactions over AR$ 3 million considered as a whole or AR$ 0.3 million considered separately.
  • Various terms are defined and clarifications are included with respect to the features of the transfer pricing analysis and supporting documentation to be prepared and submitted when an intermediary participates in related-party import or export transactions.
  • The original intention in the draft version to consider foreign related parties in the transfer pricing analysis are revised, and the new general regulation effectively returns to the rules under the former Resolution 1,122 requirement (to use only the local tested party).
  • Business restructuring rules are included to require taxpayers to disclose the rationale applied as well as other information concerning arm’s length adherence.
  • The use of local financial information in the transfer pricing analysis is confirmed and aligns with regulations issued by the Argentine Federation of Accountants.

The general resolution also provides a new set of deadlines for past fiscal years beginning from December 2018, and establishes that transfer pricing studies (filed with an affidavit on Form 2668) and Master file reports corresponding to the tax periods ending between 31 December 2018 and 30 April 2020 (inclusively) are to be filed by taxpayers or responsible parties, in the months of June, August, and October 2020, according to the following schedule for tax periods closing:

  • From December 2018 to May 2019—to be filed in June 2020
  • From June 2019 to November 2019—to be filed in August 2020
  • From December 2019 to April 2020—to be filed in October 2020

The exact dates for filing are established and are based on the last digits of the taxpayer identification number (Clave Única de Identificación Tributaria (CUIT)).

For years after these special deadlines, the transfer pricing reporting due date will be in the sixth month after the fiscal year-end while the Master file will be required to be filed during the 12th month after the fiscal year-end. 


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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