By Sandra Diaz, partner, Basa Firma, Argentina
Argentina’s Federal Administration of Public Revenues published on May 27 general resolution 4496/19 which established changes to Argentina’s transfer pricing requirements.
The resolution, which modified the RG 1122/01, makes trusts as subject to Argentina’s transfer pricing rules, eliminates the Form F.969, and unifies the due dates of Forms 743, 741, and 4501.
The new guidance also increases the threshold for filing Form 867. The form must be filed when import and export transactions between unrelated parties are greater than AR 10 million (USD 225,000).
In the case of the related parties and taxpayers located in uncooperative countries or countries with low or no taxation, transactions must be analyzed if they individually exceed AR 300,000 (USD 6,759), and exceed AR 3 million (USD 67,590) combined.
These changes are applicable for fiscal years starting January 1, 2018. The first due date under the new regime is August 2019.
Sandra L. Diaz
Sandra L. Diaz is partner at BaseFirma’s International Transfer Pricing Group for Argentina and Uruguay. Sandra is nationally known for her expertise in the area of transfer pricing and international tax where she has advised multinational companies in Latam.
She is a member of the department of fiscal policy of the Argentine Industrial Union (UIA) and an active member of the association of fiscal studies (AAEF).
She has published articles and books related to her professional field.
Sandra is a public accountant and an MBA from the Universidad de Buenos Aires.
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