AMC Consulting
Yesterday, ARCA realeased the draft amendment to the Transfer Pricing regulations. Based on the experience gained since the current framework came into effect, the Agency proposes to refine certain criteria and scopes, which would ultimately replace General Resolutions 4717 and 5010.
The Executive Branch has published Decree 767/2025, introducing significant changes to the Income Tax regime and Transfer Pricing regulations. The decree substantially updates the reporting thresholds: the limit for filing Form F.2668 for transactions with independent parties increases from ARS 10 million to ARS 500 million, while the thresholds for reporting transactions with related parties or with non-cooperative or low-tax jurisdictions rise to ARS 150 million and ARS 15 million, respectively.
Recently, the Revenue and Customs Control Agency (ARCA) has intensified its supervision of international transactions concerning Transfer Pricing (TP) compliance. The Agency has been sending notifications to taxpayers, notifying them of potential international transactions that may be subject to TP regulations.
On June 18, 2021, was published in the Official Gazette the Federal Administration of Public Revenues (“AFIP“) General Resolution 5010/2021 (“RG 5010“), applicable to fiscal years ending on December 31, 2020 and thereafter, the main purpose of which is to establish the implementation of a Simplified Regime for International Transactions (“Simplified Regime”), and to extend for 3 (three) months the Transfer Pricing (“TP”) filing due dates, moving them to the end of next September.
Argentina is adapting its Transfer Pricing and related Information Regimes to international standards, mainly based on the document issued by the Organization for Economic Cooperation and Development (“OECD”) in 2015, which details an exhaustive action plan to prevent base erosion and profit shifting, known as “BEPS”.
In 2017, through Law 27.430, amendments were introduced in the Income Tax Law (ITL) (Decree 824/19). Among these amendments, article 20 was incorporated, providing the following: “For all purposes provided for in this law, any reference to “jurisdictions with low or null taxation” shall be understood as referring to those countries, domains, jurisdictions, territories, associated states or special tax regimes that establish a maximum income tax rate of less than sixty percent (60%) of the rate referred to in article 73 (a) of this Law.” The rate referred to in article 73 of the ITL is 25%. At the…
A few days ago, AFIP began an extensive campaign of requirements to taxpayers for compliance with two Information Regimes related to Groups of Multinational Entities (MNGE). It is, on the one hand, the Register of Related Parties, and on the other, the Information Regime for entities that are part of a GEMN. As for the Register of Related Parties, it is an information regime that had been implemented by AFIP in 2013 (General Resolution “GR” AFIP 3572/2013) with two chapters. Chapter I consisted of a web service created to register all related parties (domestic or foreign) (“the Registry”); while…