The government has issued a Decree No.1112/2017 on December 29, 2017, for enacting and making effective of comprehensive tax reform. It also contains the new rules for transfer pricing. According to the new Law, transactions with parties in low-tax jurisdictions are also subject to transfer pricing scrutiny.
A new chapter is also included to the tax procedure law that includes rules for regulating unilateral APAs with the Argentine tax authorities.
Failure to submitting CbC report would be subject to a penalty ranges from AR$ 600,000 to 900,000 and for CbC notification failure, penalties are ranging from AR$ 80,000 to 200,000.
