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

February 9, 2021
2021-5157

Argentina and US agree to exchange Country-by-Country reports on large multinationals

The United States (US) Internal Revenue Service and the Argentine tax authorities (AFIP) have signed a competent authority agreement on Base Erosion and Profit Shifting (BEPS) Action 13.

Even though the text of the agreement is not yet available, it should allow the exchange of Country-by-Country (CbC) reports required in Argentina by General Resolution (GR) 4,130/2017.

Once the agreement enters into force, Argentine entities with controlling ultimate parent entities in the US should not file CbC reports in Argentina if the ultimate parent entity did so in the US. Those Argentine entities will have to comply, however, with the rest of the GR 4,130/2017 requirements, such as the first and second notification.

As stated in GR 4,130/2017, an agreement only applies when published on the AFIP´s website. As of this Tax Alert’s publication date, the AFIP’s website does not include the agreement. The publication of the agreement should include the agreement’s entry into force date.

We will issue an additional Tax Alert as more information becomes available.

_______________________________________________________________________________________________________________

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

ATTACHMENT

 
 

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 ey.com. Please refer to the privacy notice/policy on these sites for more information.


Yes, I accept         Find out more