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Home Locations Argentina

WTS in Argentina

Latin America

Buenos Aires
Buenos Aires
Rosso Alba & Rougès
Av. Leandro N. Alem 584, 10th floor
C1001AAQ Buenos Aires
https://www.rossoalba.com
+54 11 3990-8601
crossoalba@rayrlaw.com

Our local partner firm is Rosso Alba & Rougès.

Rosso Alba & Rougès, was established in Buenos Aires, in 2014 as an interdisciplinary boutique law firm with 24 professionals. It has strong tax, commercial, customs and corporate expertise, and has been historically ranked as a top tier firm for its international tax, transfer pricing and M&A capabilities.

Rosso Alba & Rougès currently advises half of the twenty largest exporting companies in Argentina; including both multinationals and locally-controlled companies. Due to its unique international tax and transfer pricing expertise, coupled with an excellent academic reputation, it is regularly called to lecture at major domestic and foreign universities, and to advise governmental institutions such as the Inter-American Development Bank. Its clients are focused on a variety of fields, like the oil & gas industry; primary production and biodiesel exports; the automobile industry; the food and service industries, as well as regulated entities and mining companies. The firm has a remarkable team devoted to trusts and wealth management advice, pursuing a comprehensive approach from the international tax, Civil Law and Conflicts of Laws viewpoints. On transfer pricing grounds, it is one of few law firms with in-house economists and accountants, teaming up with specialized tax lawyers; and has recently won the leading cases of Glencore and ADM groups before the Federal Supreme Court.

Main Contact
Cristian E. Rosso Alba
Managing Partner
WTS Global Transfer Pricing LATAM Regional Leader
Argentina
https://www.rossoalba.com
+54 11 4877 7006
View Profile

Local News

The Argentine Tax Court has recently ruled on an interesting Transfer Pricing case, concerning the timing of benchmarking a transfer of goods. Further details about this case can be found in the article.

Argentine Tax Court ruling on Transfer Pricing Case
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As of 30 August 2022, the Argentine Revenue Service (“ARS”) decided to suspend the Mandatory Disclosure Framework (“MDF”), which was created by the agency by means of general resolution no. 4838/2020, enacted in October 2020.

Suspension of the Argentine Mandatory Disclosure Framework
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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

Tax court rules on PE under Belgium-Argentina tax treaty
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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.

Argentina: Deemed Affiliation - Cross-Border Transactions with Low-Tax Jurisdictions
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The tax framework for leasing transactions – included in Decree No. 1038/2000 (“DL”), as amended – has recently been modified. 

Argentina: Financial Lease Transactions: Changes in the Tax Framework
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The Argentine Supreme Court (“ASC”) ruled on the Molinos case, a milestone one related to treaty shopping.

Argentine Supreme Court rules on treaty shopping in the context of the Argentina-Chile Double Tax Treaty
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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.

Argentina: Tightening of the foreign exchange control framework, increase of Corporate Income Tax, taxation of crypto currencies, & Supreme Court decision on interest deduction
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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.

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

Argentina: Mandatory Disclosure Framework and Transfer Pricing
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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.

Argentina adds new transfer pricing documentation requirements for operations with intermediaries
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Our colleagues from Argentina provide an overview of the new transfer pricing regulations by summarising the six main aspects of GR4717.

Argentina: “Argentine Transfer Pricing News - 2020 Second Trimester”
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Learn all about the major Argentinian transfer pricing developments, that are noteworthy in the year 2020.

Argentina: Transfer Pricing News – 2020 First Trimester
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Show more

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