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Argentina: Country-by-country reporting rules
Argentina: Country-by-country reporting rules
Resolution N° 4,130-E, published in the official gazette (20 September 2017), sets forth the requirements for country-by-country (CbC) reporting in Argentina.
The measures in Title 1 of the resolution generally reflect standard CbC reporting requirements—for example, the €750 million threshold and type of information to be reported—pursuant to the OECD’s base erosion and profit shifting (BEPS) Action 13 initiative. The rules in Argentina are effective for fiscal years beginning on or after 1 January 2017.
Filing the CbC report
The CbC reporting rules apply to “ultimate parent companies” of multinational enterprise (MNE) groups that are residents of Argentina. The CbC reporting rules also apply with respect to certain domestic taxpayers that are part of a MNE group if: (1) there is no obligation to comply with the CbC rules in the jurisdiction where the ultimate parent company is a resident; (2) there is no competent authority agreement with the jurisdiction of the ultimate parent company that allows the Argentine tax authorities to obtain the CbC report information automatically; or (3) there are systematical failures of the jurisdiction of the ultimate parent company to submit the CbC report to Argentine tax authorities.
- Taxpayers required to comply with the CbC reporting regime will do so via the website of the tax authority (AFIP) and by obtaining form F 8097 as a proof of filing. The CbC reporting deadline is the last business day of the 12-month period after fiscal year-end of the ultimate parent company.
- Resident entities of a MNE group required to submit information about their ultimate parent company and the MNE group, among others, have a deadline of the third month after the fiscal year-end of the ultimate parent company. Also, two months after that deadline for the CbC report filing, domestic entities are also required to inform the tax authority in Argentina if the CbC report was filed in the jurisdiction of the ultimate parent company. The reporting by domestic entities will be made via the website of the tax authority (AFIP) and by obtaining form F 8096 as a proof of filing.
These CbC reporting rules are in addition to the Argentine rules for local reporting and for transfer pricing information returns pursuant to Resolution N° 1,122.
For more information, contact a KPMG tax professional in Argentina:
Marcelo Castillo | +54 11 431 65 891 | macastillo@kpmg.com.ar
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