The Argentine tax administration (AFIP) extended the deadline for taxpayers to comply with a notification requirement under the country-by-country (CbC) reporting regime. The new deadline is 2 May 2018 for those taxpayers whose “ultimate parent company” of a multinational entity (MNE) group has a fiscal year ended as of December 2017.
Resolución N° 4218 (Spanish), published in today's edition of the official bulletin, provides additional time for those taxpayers that are part of MNE groups with a fiscal year ending in December 2017 for submitting CbC notifications.
The CbC reporting rules apply to “ultimate parent companies” of MNE groups that are residents of Argentina. The CbC reporting rules also apply with respect to certain domestic taxpayers that are part of the 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. Read TaxNewsFlash-Transfer Pricing
For more information, contact a KPMG tax professional in Argentina:
Marcelo Castillo | +54 11 431 65 891 | firstname.lastname@example.org
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