TP International Advisors

Transfer Pricing
in US

We advise companies in all kinds of projects, including preparing Supporting Documentation (Local Files), designing Transfer Pricing Policies, analyzing financial transactions, valuing intangible assets, benchmarking, and business restructuring, among others.

Transfer Pricing in
LATAM and Spain

Our practice covers Transfer Pricing compliance and consulting for all Latin American countries and Spain, supported by a specialized team with over 20 years of experience. We offer an integrated service that oversees the entire process until filing in every jurisdiction.

International
Specialization

We are a boutique consulting firm that exclusively serves companies engaged in international transactions. Our strong training program and high-quality standards are designed to exceed our clients' expectations in every deliverable.

Regional
Projects

We lead regional projects across all Latin American countries where our clients operate. Having a centralized team allows our clients to achieve economies of scale, maintain uniform criteria in their economic analyses, streamline communication, facilitate project monitoring, and minimize the production and circulation of information. This makes working with TP International Advisors the best cost-effective decision.

Latest news:

Simplified Regime for International Operations and Amendments to RG AFIP 4717/2020

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. Additionally, RG 5010 establishes that the Simplified Regime will be formalized through the filing of the affidavit form F.2672, and modifies the TP regulations (amending…

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AFIP focuses on Argentine companies belonging to Multinational Groups

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 this sense, the Federal Administration of Public Revenues (“AFIP”) puts rigor to compliance with General Resolution 4130-E/2017 (“G 4130”), through requirements to taxpayers for lack of compliance with said information regime. GR 4130 established the following obligations: 1) Information Regime for Argentine entities which are part of a Multinational Group of Entities…

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Countries or Jurisdictions with Low or Null Taxation

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…

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AFIP´s Compliance Requests

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…

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