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Argentina: Unified requirements, deadline for transfer pricing reports and returns

Argentina: Transfer pricing reports and returns

The requirements and deadline for filing transfer pricing reports and returns has been unified with the issuance of General Resolution 4496/19.

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Resolución General 4496/2019 (Spanish) was published in the official gazette on 27 May 2019. With this guidance, the tax administration (Administración Federal de Ingresos Públicos—AFIP) introduced amendments to existing guidelines (General Resolution 1122/01) for complying with the transfer pricing regulations.

Among the changes:

  • Effective for tax years beginning on or after 1 January 2018, the due date for filing transfer pricing information returns on forms F 741, F 743, and F 867 (that is, the information returns that are required for various types of transactions)—as well as the transfer pricing local report and the required CPA certification (both of which are required pursuant to form F 4501)—will be due in the eighth month after the fiscal year-end.
  • The threshold amount of related-party transactions that requires the filing of forms 743 and 4501 has been established as: (1) 300,000 pesos for the amount of separate transactions; or (2) 3 million pesos for the sum total of related-party transactions. This confirms the thresholds introduced by Decree 1170/18. Read TaxNewsFlash
  • The minimum threshold required for taxpayers to file form F 867 will be 10 million pesos, whereas there is no minimum threshold required for filing form F 741.
  • While it may no longer be necessary to file form F 969, most of the information that was required by form F 969 must now be included on form F 743.

KPMG observation

It was expected that guidance from the tax authorities would have clarified the following two areas of uncertainty with regard to the transfer pricing reporting requirements: (1) the Master file requirements that were referenced in Decree 1170/18; and (2) the reporting requirements when an intermediary is part of the transaction. Given these areas of continued uncertainty, tax professionals believe that future guidance may offer some clarity about these two elements.

 

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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