Argentina: Exchanges of country-by-country reports, agreement with United States

Argentina: Exchanges of country-by-country reports

An agreement between the Competent Authorities of Argentina’s tax administration (AFIP) and the U.S. tax agency (IRS) concerns the process for the automatic exchange of country-by-country (CbC) reports.


The first exchange of CbC reports will concern fiscal years beginning on or after 1 January 2018, with the CbC reports to be exchanged as soon as possible but no later than 15 months after the last day of the fiscal year of the multinational corporate group. The information exchanged through the CbC reports will be used by the tax authorities to assess certain risks such as erosion of the tax base and risks related to the transfer of profit and, when appropriate, for economic and statistical analysis.

The tax administrations are not to use the exchanged information as a substitute for a detailed analysis of transfer pricing (whether a complete functional analysis or comparability analysis), and are not to treat the information contained in the CbC reports as conclusive evidence that the transfer prices are appropriate (or not). Thus, transfer price adjustments are not to be based on information in the exchanged CbC reports.

Still, the data in the CbC reports can be used as the basis for further investigation of multinational entities’ transfer pricing agreements or other tax matters in the course of a tax audit and, as a result of such additional inquiries, adjustments can be made.

The agreement between AFIP and the IRS is within the framework of Action 13 of the base erosion and profit shifting (BEPS) project.

Read a February 2021 report (Spanish) prepared by the KPMG member firm in Argentina

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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