After four extensions over the past year, the final Argentina Transfer Pricing Documentation Regulations (General Resolution N 4717) have been published and these final regulations are effective for the fiscal year ending December 31, 2018 and onward.
Argentinean taxpayers should carefully review these new rules because they may impact the content of their transfer pricing studies. The rules include content and technical guidelines to prepare transfer pricing documentation from FY 2018 and forward.
The Regulations provide more clarity about the content and methodology needed to comply with the arm’s length principle in a way that is consistent with the OECD guidelines and other local transfer pricing legislation in Latin America. They also increase the documentation burden for a greater number of taxpayers, as well as increasing the complexity of the required studies and the annual process for submitting documentation.
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