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

May 28, 2020

Argentina issues long-awaited transfer pricing regulations

On 15 May 2020, the Argentine Federal Tax Authorities (AFIP – Administración Federal de Ingresos Públicos) published, in the Official Gazette, General Resolution No. 4717 (GR 4717), containing the long-awaited regulations implementing the transfer pricing (TP) provisions enacted as part of the tax reform in December 2017. These rules mainly cover the TP compliance obligations for fiscal years ended December 2018 and onwards (including due dates and the creation of new returns). Those compliance obligations include the filing of the TP report (local file) and master file. Additionally, the regulations introduce definitions and requirements that will impact existing and future intercompany transactions involving Argentine companies. Multinational companies doing business in Argentina should review the new regulations and assess their intercompany transactions.

Compliance obligations and due dates

The TP report and master file were due beginning the week of 18 May 2020. GR 4717 extends the filing due dates for Form 2668, TP report, and the master file as follows:

  • For tax years ending December 2018 to May 2019, the due date is from 10 June to 14 June 2020.
  • For tax years ending June 2019 to November 2019, the due date is from 10 August to 14 August 2020.
  • For tax years ending December 2019 to April 2020, the due date is from 10 October to 14 October 2020.

After 2020, the filings will be due as follows:

  • Form 2668 and the TP report will be due from the 23rd to the 27th of the sixth month following the year-end.
  • The master file will be due from the 23rd to the 27th of the 12th month following the year-end.

Taxpayers will have to report:

  • Cross-border transactions between Argentine residents and foreign related parties
  • Transactions between Argentine residents and independent parties located in “non-cooperating” jurisdictions or “low or no tax” jurisdictions
  • Import and export transactions conducted with independent parties for values exceeding ARS10 million (approximately US$143k) per tax year

The regulations include several rules to determine which transactions need to be reported and the information required for each of them. To determine whether a transaction has to be reported, taxpayers should consider certain factors, such as the amount of the transactions (stand-alone and aggregated) and whether they belong to an economic group subject to the filing of a master file or the country-by-country (CbC) report. Because of the low thresholds established in GR 4717 and the interaction of various regulations, it is highly likely that most Argentine entities conducting transactions with foreign related parties will be required to perform at least one of the following TP filings:

  • Form 2668 (including Form 4501 with the electronic signatures of the taxpayer’s representative, the Certified Public Accountant or economist authenticated by the local body governing the professional registry)
  • TP report
  • Master file

Filings related to the CbC report continue to be regulated through AFIP’s General Resolution 4130/2017.

Definitions and concepts applicable to the analysis of cross-border transactions

In addition to the general framework for TP compliance, GR 4717 introduces fundamental definitions and requirements that will impact the planning and implementation of intercompany transactions involving Argentine companies. Specifically, GR 4717 requires taxpayers to perform a segmented analysis for each business line and an analysis based on accounting information adjusted for inflation (according to Argentine GAAP). It also requires taxpayers to follow the local tested-party rule.

Additionally, GR 4717 provides specific criteria for the analysis of:

  • Intragroup services
  • Financial operations
  • Transactions involving intangible assets
  • Research and development activities, including contract R&D
  • Exports of goods with public prices

GR 4717 allows taxpayers to use “other TP methods” in certain instances, such as:

  • Operations involving unique, valuable and specific goods or rights that do not have comparables or are difficult to assimilate to other goods or rights
  • Transfers of shares or participations in companies that are not listed in stock exchange markets
  • Transfers of intangible assets

For transactions involving international traders, GR 4717 establishes:

  • New characteristics that shape the definition of international traders
  • Requirements for performing a functional analysis of international traders
  • Requirements for documenting arm’s-length remuneration obtained by international traders
  • The information to be obtained and kept regarding international traders

It also defines business restructurings and the minimum information that should be included in the TP report, as well as the local requirements for filing the master file.


Companies should carefully assess the obligations with which they must comply and consider implementing alternative processes for intercompany transactions in light of the new definitions and specific criteria established for different issues. Failure to comply with this new legislation may result in penalties and increase the probability of being audited by the tax authorities.

This Tax Alert only presents an initial overview of the main developments contained in GR 4717, but the resolution could have significant implications for companies doing business in Argentina. Companies may have to perform a detailed analysis of financial operations, service provisions and transactions involving intangibles or intermediaries, among others.


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

Pistrelli, Henry Martin & Asociados S.R.L., Buenos Aires
Ernst & Young LLP (United States), Latin American Business Center, New York
Ernst & Young Abogados, Latin American Business Center, Madrid
Ernst & Young LLP (United Kingdom), Latin American Business Center, London
Ernst & Young Tax Co., Latin American Business Center, Japan & Asia Pacific



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 © 2024, 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 Opt out of all email from EY Global Limited.


Cookie Settings

This site uses cookies to provide you with a personalized browsing experience and allows us to understand more about you. More information on the cookies we use can be found here. By clicking 'Yes, I accept' you agree and consent to our use of cookies. More information on what these cookies are and how we use them, including how you can manage them, is outlined in our Privacy Notice. Please note that your decision to decline the use of cookies is limited to this site only, and not in relation to other EY sites or Please refer to the privacy notice/policy on these sites for more information.

Yes, I accept         Find out more