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…

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…