Briefly describe the transfer pricing documentation and taxreturn disclosure requirements in your jurisdiction.
Transfer pricing tax compliance is certainly cumbersome in Argentina. The relevant reportable transactions include not only related party transactions and deemed related party transactions but also certain data on cross-border unrelated party transactions. A summary of the relevant reportable information in each case is provided below.
As a general rule, no tax filing is due only in the following cases: (i) the taxpayer has not performed any
international transactions with affiliated companies (i.e., including those with counterparties domiciled in
countries considered by the Argentine Revenue Service (‘‘ARS’’) as non-cooperative for tax-information
exchange and low-tax jurisdictions); or (ii) it has performed cross-border transactions with unrelated parties that do not involve commodities and/or are not material enough to exceed the minimum reportable threshold.