On 27 May 2019, the Federal Administration of Public Revenue (AFIP) has published General Resolution 4496 (GR 4496) in the official gazette amending General Resolution 1122 (GR 1122). The resolution explains requirements, deadline, thresholds for transfer pricing (TP) reports and returns. The significant changes are as follows:
Forms
The resolution clarifies that the taxpayers must file all transfer pricing forms including forms F.741, F.743, F.867 and F.4501 and the related documentation in the first week of the eighth month following the close of the tax year. The resolution eliminates form F.969, most of the information now included as part of form F. 743.
New thresholds
For filling form F.743 and F.4501, the required thresholds:
- Individual transactions exceeding ARS 300,000 during the period; or
- Aggregate transactions exceeding ARS 3 million.
For filling form F.867, the transaction threshold is increased from ARS 1 million to ARS 10 million. Moreover if said transactions exceed ARS 100 million, taxpayers must maintain form F.867. On the other hand there is no filling threshold for form F.741.
Effective date
The resolution came into effect as of its publication date and applies for the fiscal year starting on or after 01 January 2018.
