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 | +54 11 431 65 891 | firstname.lastname@example.org
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