Argentina Modifies Transfer Pricing Regime

; posted on
May 31st, 2019

Argentina’s Federal Administration of Public Revenues published General Resolution 4496/19, which established changes to Argentina’s transfer pricing requirements. One of the purposes of the regulation is harmonizing the filing deadlines for various transfer pricing return obligations.

Details

The resolution establishes one due date for the various Argentine transfer pricing forms. Under General Resolution 4496, taxpayers must file all transfer pricing forms, when applicable, and the related documentation in the first week of the eighth month following the close of the tax year. The transfer pricing forms include Forms 741, 743, 867 and 4501 with the detail as follow:

  • Form F. 741, on commodity import/export transactions with unrelated parties not resident in non-cooperative or low/no tax jurisdictions;
  • Form F. 867, on other non-commodity import/export transactions with unrelated parties not resident in non-cooperative or low/no tax jurisdictions. This form is requires to the extent taxpayers have transactions of at least ARS10 million or more (US$222,222);
  • Form F. 743, on transactions with related parties and unrelated parties resident in non-cooperative or low/no tax jurisdictions; and
  • Form F. 4.501, for the CPA certified transfer pricing study and financial statements. Taxpayers must file this form and F.743 form if they have transactions that individually exceed ARS300,000 or as a whole exceed ARS3 million (approx.1 US$6,666 and US$66,666).

Deadlines related to the Argentine country-by-country report filings remain unchanged.

Companies conducting business in Argentina should aware of the changes laid out in the general resolution as it gives impact on business and transfer pricing compliance.

Date of enforcement

General Resolution 4496/2019 entered into force on 27 May 2019 and applies in respect of fiscal years beginning on or after 1 January 2018.

Source: Official Gazette of Argentina

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