Argentina: Extended due date for filing transfer pricing reports; other reporting relief measures

Extended deadline for filing transfer pricing reports, tax years ending in 2020 or 2021

The deadline for filing transfer pricing reports has been extended.

Guidance published in today’s edition of the official gazette extends the deadline for filing transfer pricing reports for tax years ending in 2020 or 2021 as well as providing other reporting relief measures.

The tax authority (AFIP) issued Resolución General 5010/2021 (Spanish) (18 June 2021) to grant an extension of time for filing transfer pricing reports and related forms F. 2668 and F. 2672 for tax years ended between 31 December 2020 and 31 December 2021, inclusive. The new due date falls in the ninth month following the end of the tax year, with the deadline starting on the 23rd day of the month for taxpayers with a taxpayer identification number (Clave Única de Identificación Tributaria—CUIT) ending in 0-1 and so on.

In addition, other measures included in today’s guidance provide:

  • An optional international operations simplified regime to be realized though the filing of new form F. 2672, Operaciones Internacionales Régimen Simplificado (International Operations Simplified Regime). There are certain conditions and specific information requirements for taxpayers to be eligible for this regime.
  • Changes regarding the obligation to submit a Master file. The Master file must be submitted when the following two conditions are met:
    • The taxpayer group's consolidated annual revenue exceeds ARS 4 billion in the previous tax year (the tax year prior to the filing).
    • Transactions with foreign related parties during the tax year exceed ARS 3 million in the aggregate or ARS 300,000 individually.

However, if there have been no changes to the information for the current reporting period from the information disclosed in the most recently filed Master file, taxpayers may file an affidavit stating that there have been no changes (instead of filing a Master file). The group’s consolidated financial statements for the reporting period are to be attached to the affidavit.

KPMG observation

The extended deadline and other relief measures generally recognize the effects of the coronavirus (COVID-19) pandemic and the challenges that taxpayers may encounter with regard to information about their cross-border transactions during the tax year ending in 2021.


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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