The requirements and deadline for filing transfer pricing reports and returns has been unified with the issuance of General Resolution 4496/19.
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:
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 | firstname.lastname@example.org
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