On 2 October 2019, tax authority of Argentina (AFIP) announced a public consultation and posted on the AFIP website a draft resolution concerning transfer pricing compliance procedures. It would replace the existing transfer pricing rules in General Resolution 1122/2017.
According to this new Resolution, a way in where foreign party is considered as tested party was introduced. The tax authority asked foreign companies to provide key information such as audited and certified financial statements and TP reports. It describes how groups should ensure that their transactions with related parties are conducted on arm’s length terms, and provides detailed guidance on how to select comparables and treat intangible assets. It also covers transfer pricing documentation requirements, thresholds and timelines.
Companies with intra-group transactions of more than ARS 9 million (approximately $ 155,000) must submit a transfer pricing report. This guide also asked for a new Disclosure Form (F. 2668) for all international transactions (with third parties) and intra-group transactions subject to certain conditions. Taxpayers with intra-group transactions of more than ARS 500 million (approximately $ 8.6 million) must submit a master file. The proposed deadline for the submission of the transfer pricing documentation, including the transfer pricing report, the disclosure form F2668 and the master file, is six months after the end of the financial year.
