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Law 27,430 was published on 29 December 2017. The main changes introduced by the Tax Reform with regard to Transfer Pricing are detailed below:

  • Implementation of the Mutual Agreement Procedure (MAP).
  • Implementation of Advanced Transfer Pricing Agreement (APA).
  • Definition of low tax jurisdictions and of jurisdictions non-cooperative in the exchange of tax information.
  • For export/import transactions of products with international intermediaries, it must be proved that the remuneration obtained relates to the risks assumed, the functions performed and the assets involved in the operation.
  • Registration before the Federal Administration of Public Revenues ("AFIP" by its acronym in Spanish) of agreements corresponding to the operations of export of goods with quotation in which an international intermediary intervenes.
  • Definition of permanent establishment.
  • Fines applicable to non-compliance with the information regime of the country-by-country reporting.

The aforementioned changes are effective for fiscal years beginning on or after the 1st of January 2018.

It is worth noting that additional regulations are pending of publications.

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