WTS in Argentina

The Argentine Revenue Service (“ARS”) considered that the Belgium Company Solvay S.A. (“Solvay”) had a PE in the country during the years 2001 to 2006

The Argentine Income Tax law includes a large number of “deemed affiliated” companies. All of them must be scrutinized in the annual Transfer Pricing report, which needs to be filed mandatorily with the Argentine Revenue Service.

The tax framework for leasing transactions – included in Decree No. 1038/2000 (“DL”), as amended – has recently been modified. 

The Argentine Supreme Court (“ASC”) ruled on the Molinos case, a milestone one related to treaty shopping.

In an attempt to reduce the drain of the Argentina Central Bank (“ACB”) dollar reserves and the continuous shortage of foreign currency, the Argentine Securities Exchange Commission (“ASEC”) issued General Resolution No. 907/21, which was published in the Official Gazette on October 6, 2021.

The Argentine Revenue Service has made available a document with recommendations and suggestions for the Transfer Pricing analysis (the “document”) to be conducted for the fiscal years impacted by the COVID-19 pandemic.

Our colleagues from Argentina provide an overview of the new mandatory disclosure framework for domestic and international tax planning arrangements.

The Argentine Revenue Service has added new transfer pricing documentation requirements for operations with intermediaries. More specifically, the requirements for transfer pricing documentations have been extended with a focus on imports and exports through international intermediaries.

Our colleagues from Argentina provide an overview of the new transfer pricing regulations by summarising the six main aspects of GR4717.

Learn all about the major Argentinian transfer pricing developments, that are noteworthy in the year 2020.