Sign up for tax alert emails    GTNU homepage    Tax newsroom    Email document    Print document    Download document

February 25, 2019

Argentina issues procedure for registering and processing imports under related-party agreements containing price review clauses

On 7 February 2019, Argentina published, in the Official Gazette, General Resolution No. 4419 (GR 4419), which establishes the procedure for registering and processing imports of goods under related-party agreements containing price review clauses. The procedure in GR 4419 only applies when third-party operators mediate the import transactions between the related parties.


Related sellers and importers commonly enter into agreements with price-review clauses, which allow for changes to the price of imported goods after they clear customs. Many of these import transactions use a third-party operator related to the seller and the importer.

To prevent taxpayers from underreporting the tax liabilities associated with imports and overbilling for imports, the tax authorities have issued GR 4419.

GR 4419

GR 4419 requires importers to file a copy of the agreement containing the price review method with the Related Companies Division of the Argentine Customs Authorities before registering the imports in the Argentine Customs IT system.

When registering the imports in the Argentine Customs IT system, taxpayers should submit the import statement with a temporary value declaration, which the Customs Authorities will review. The importer may amend this declaration based on the reported contractual terms.

The importer should pay the taxes when the import statement is filed, even though additional charges (i.e., late payment) may be levied later.

Within 180 calendar days after the tax period ends, the importer should file the following information with the Related Companies Division: (i) documentation supporting the final value of the goods under the agreement filed, and (ii) information on each statement identifying: (a) the third-party operator; (b) the price documented with the country of origin’s Customs Authorities; (c) the price documented with Argentina’s Customs Authorities, and (d) the billing margin and type of product (direct resale or input).

The submission of the documentation supporting the final value of the goods under the agreement filed will not result in the automatic validation by the Customs Authorities of the value declared.

At the end of each tax period, the importer should also file with the Related Companies Division (i) financial statements or equivalent documentation of the operator that consolidates the transactions of the group of companies at a global level, and (ii) the third-party operator’s financial statements or the documents that show the third-party’s costs in mediating the import transaction.

Because the import taxes are based on the price of importation and agreements with price-review clauses allow prices to change once the goods are imported, GR 4419 requires importers to pay the additional import taxes due as a result of the price difference plus interest.

For additional information with respect to this Alert, please contact the following:

Pistrelli, Henry Martin & Asociados S.R.L., Buenos Aires
  • Carlos Casanovas |
  • Gustavo Scravaglieri |
  • Ariel Becher |
  • Darío Corrente |
Ernst & Young, LLP, Latin American Business Center, New York
  • Pablo Wejcman |
  • Juan Ignacio Pernin |
  • Ana Mingramm |
  • Enrique Perez Grovas |
Ernst & Young LLP (United Kingdom), Latin American Business Center, London
  • Pablo Baroffio |
  • Jose Padilla |
Ernst & Young Tax Co., Latin American Business Center, Japan & Asia Pacific
  • Raul Moreno, Tokyo |
  • Luis Coronado, Singapore |



The information contained herein is general in nature and is not intended, and should not be construed, as legal, accounting or tax advice or opinion provided by Ernst & Young LLP to the reader. The reader also is cautioned that this material may not be applicable to, or suitable for, the reader's specific circumstances or needs, and may require consideration of non-tax and other tax factors if any action is to be contemplated. The reader should contact his or her Ernst & Young LLP or other tax professional prior to taking any action based upon this information. Ernst & Young LLP assumes no obligation to inform the reader of any changes in tax laws or other factors that could affect the information contained herein.


Copyright © 2023, Ernst & Young LLP.


All rights reserved. No part of this document may be reproduced, retransmitted or otherwise redistributed in any form or by any means, electronic or mechanical, including by photocopying, facsimile transmission, recording, rekeying, or using any information storage and retrieval system, without written permission from Ernst & Young LLP.


Any U.S. tax advice contained herein was not intended or written to be used, and cannot be used, by the recipient for the purpose of avoiding penalties that may be imposed under the Internal Revenue Code or applicable state or local tax law provisions.


"EY" refers to the global organisation, and may refer to one or more, of the member firms of Ernst & Young Global Limited, each of which is a separate legal entity. Ernst & Young Global Limited, a UK company limited by guarantee, does not provide services to clients.


Privacy  |  Cookies  |  BCR  |  Legal  |  Global Code of Conduct