The Federal Tax Administration (FTA), on September 20, 2017, published the General Resolution 4130-E in the Official Gazette. It establishes the country-by-country (CbC) guiding framework in Argentina and is applicable to ultimate parent entities of multinational enterprises (MNEs) with annual revenues of EUR 750,000,000 or more, or surrogate parent entities with a net worth of at least ARS 50,000,000. These CbC reporting rules are in addition to the Argentine rules for local reporting and for transfer pricing information returns pursuant to Resolution N° 1,122.
Generally, the framework is consistent with the OECD guidelines on CbC reporting regarding information to be reported. Taxpayers need to comply with the CbC reporting regime will do so through the website of the tax authority (AFIP) and by obtaining form F 8097 as a proof of filing. Data must be submitted electronically on the tax authorities’ website and annually following the fiscal year of the period being reported. This obligation does not affect other transfer pricing information regimes already in force. The rule is effective from September 20, 2017, and applies to the fiscal year starting on or after January 1, 2017. This resolution charges penalties by Law No. 11,683 for failing to comply with the obligations set forth in it.
