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Argentina: Transfer pricing rules, implementing decree

Argentina: Transfer pricing rules, implementing decree

A decree published in late 2018 includes provisions that implement certain transfer pricing rules as previously introduced by Law 27.430 / 2017.


Related content

Among the measures contained in Decreto 1170/2018 (Spanish) are provisions: 

  • Concerning adoption of the Master file rule
  • Allowing taxpayers to apply a different transfer pricing method (instead of a traditional method) when the transaction involves the transfer of valuable and unique intangible assets or financial assets that do not present comparable transactions
  • Introducing minimum threshold requirements for filing transfer pricing returns as well as a Master file and Local file
  • Specifying detail of information about when to register contracts for exports of goods with listed prices with the Argentine tax authorities (AFIP)
  • Relating to testing the arm’s length price of transactions with an international intermediary involved in an import and/or export operation of goods
  • Reiterating the general criteria for the arm’s length pricing test as well as the use of internal comparables as a priority source of information
  • Indicating that information of the tested party must always be the one corresponding to the fiscal year at issue

Read more about the decree’s general corporate income tax provisions: TaxNewsFlash

KPMG observation

While the decree provides fairly extensive guidance, tax professionals expect that AFIP will issue supplementary guidelines providing greater detail and clarify relating to transfer pricing compliance 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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