Resolution N° 4,130-E, published in the official gazette (20 September 2017), sets forth the requirements for country-by-country (CbC) reporting in Argentina.
The measures in Title 1 of the resolution generally reflect standard CbC reporting requirements—for example, the €750 million threshold and type of information to be reported—pursuant to the OECD’s base erosion and profit shifting (BEPS) Action 13 initiative. The rules in Argentina are effective for fiscal years beginning on or after 1 January 2017.
The CbC reporting rules apply to “ultimate parent companies” of multinational enterprise (MNE) groups that are residents of Argentina. The CbC reporting rules also apply with respect to certain domestic taxpayers that are part of a MNE group if: (1) there is no obligation to comply with the CbC rules in the jurisdiction where the ultimate parent company is a resident; (2) there is no competent authority agreement with the jurisdiction of the ultimate parent company that allows the Argentine tax authorities to obtain the CbC report information automatically; or (3) there are systematical failures of the jurisdiction of the ultimate parent company to submit the CbC report to Argentine tax authorities.
These CbC reporting rules are in addition to the Argentine rules for local reporting and for transfer pricing information returns pursuant to Resolution N° 1,122.
For more information, contact a KPMG tax professional in Argentina:
Marcelo Castillo | +541143165891 | firstname.lastname@example.org
© 2018 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. All rights reserved.
Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm.
The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.