On 18 June 2021, the Federal Administration of Public Revenues (AFIP) Officially published General Resolution 5010/2021, which extends the deadline for filing transfer pricing reports and related forms F. 2668 and F. 2672 for tax years ended between 31 December 2020 and 31 December 2021. The Resolution also includes the master file reporting obligations.
Transfer pricing reports
The expiration dates for the fiscal period closed 2020 and 2021, are set according to the following detail:
| CUIT termination | Expiry date |
| 0-1 | Until the 23rd of the ninth month after the close of the fiscal year. |
| 2-3 | Until the 24th of the ninth month after the close of the fiscal year. |
| 4-5 | Until the 25th of the ninth month after the close of the fiscal year. |
| 6-7 | Until the 26th of the ninth month after the close of the fiscal year. |
| 8-9 | Until the 27th of the ninth month after the close of the fiscal year. |
Master file reporting obligations
According to the Resolution, taxpayers having total consolidated annual income of the group exceeds 4 million pesos in the year prior to the presentation or transactions carried out with related parties abroad exceed, as a whole, in the fiscal period, the amount equivalent to 3 million pesos or individually of 300 thousand pesos are subject to submit master file. However, if there have been no changes to the information for the current reporting period from the information disclosed in the most recently filed Master file, taxpayers may file an affidavit instead of filing a Master file stating that there have been no changes. Note that, the group’s consolidated financial statements for the reporting period are to be attached to the affidavit.
