On 15 May 2020, the Argentine tax authorities (AFIP) Officially published General Resolution 4717/2020 of 14 May 2020, which governs the control of transfer prices of international transactions. The new resolution replaces General Resolution No. 1122, and other complementary regulations. The provisions of the new Resolution came into effect on 15 May 2020 and are applicable for fiscal years ending on or after December 31, 2018. The applicable due dates start as from June 2020. The Resolution includes some important provisions regarding transfer pricing:
- Process of how to calculate annual aggregate thresholds for entities.
- The reporting threshold applied to transactions with unrelated nonresidents domiciled in non-cooperating or low tax jurisdictions.
- Methods for electronic sworn declarations and financial statements.
- Reporting requirements for import and export operations.
- documentation to determine income taxes on profits from imports and exports.
- Conditions required for comparability adjustments. And
- Special deadlines are extended until June, August, and October based on the fiscal years end between 31 December 2018 and 30 April 2020 for the filing of the transfer pricing report, Form No. 2668, and the master file.
