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Argentina: Transfer pricing compliance rules, reporting deadline deferred to July 2020

Argentina: Transfer pricing compliance rules

The Argentine tax authorities (AFIP) today released for publication in the official bulletin a general resolution that reflects an extended deadline of July 2020 for certain transfer pricing reporting for tax periods from December 2018 to May 2019.

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Previously, reporting for this prior period was due in June 2020. 

Summary

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). Implementation of the transfer pricing rules had been postponed by a number of prior resolutions, but ultimately were finalized in May 2020. Read TaxNewsFlash

Today’s release—Resolución General 4733/2020 (Spanish)—generally reiterates the implementation measures that were finalized in May 2020, but indicates a change to the reporting deadline for the tax periods ending from December 2018 to May 2019.

The revised schedule for reporting deadlines for past fiscal years beginning from December 2018, and for transfer pricing studies (that are 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 July, August, and October 2020, for tax periods closing:

  • From December 2018 to May 2019—to be filed in July 2020 (instead of June 2020 as provided in the May 2020 guidance)
  • 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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