The Argentine Federal Tax Authorities issued General Resolution N° 3,476 on 10 April 2013. The Resolution has revised the transfer pricing compliance rules and introduced modifications to the current Transfer Pricing regulations.
General Resolution N° 3,476 has amended General Resolution N° 1122/01, which was issued by the AFIP in 2001 to establish certain formalities and other requirements that taxpayers must satisfy if they are subject to Argentina’s transfer pricing rules.
According to General Resolution N° 3,476, the electronic filing of the report containing the transfer pricing analysis, including the certification issued by an independent certified public accountant (CPA), is to be done using a “pdf” format. To comply with the revised rules, a new transfer pricing form (F. 4501) has been introduced for taxpayers to use which must be filed with the transfer pricing report and the CPA’s certification. If there is a need to attach a public translation of foreign language content, that will have to contain a notary public’s digital signature. This process also requires that a Level 4 – “Digital Certificate” is granted by the certifying authority of the AFIP.
