AFIP General Resolution No. 4717/2020 | Transfer Pricing Regime: new regulations
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Tax Department Report | AFIP General Resolution No. 4717/2020 | Transfer Pricing Regime: new regulations
In accordance with the amendments introduced by Law No. 27.430 (Tax Reform) and Decree No. 1.170/2018, the Federal Tax Authority (AFIP) issued the General Resolution No. 4717/2020, stating a new transfer pricing regulation regarding international transactions (General Resolution No. 1122/2002 is thus abrogated).
Pursuant to this new regulation, the AFIP stated new assessment rules regarding transfer pricing transactions as well as new conditions in relation to the conservation and filing of the required documentation.
Moreover, the Resolution establishes the Form No. 2.668 (annual return), a new scope for the Transfer Pricing Analysis and a Master File, which is subject to particular specifications.
The provisions of this Resolution are mandatory for fiscal years ended as from December 31st, 2018. Special deadlines are established for the filing of the Transfer Pricing Report, the Form No. 2668 and the Master File regarding fiscal years ended between December 31st, 2018 and April 30th, 2020:
• FY ended between December 2018 and May 2019: deadline between June 10th, 2020 and June 14th, depending on the taxpayer’s Tax ID.
• FY ended between June 2019 and November 2019: deadline between August 10th, 2020 and August 14th, depending on the taxpayer’s Tax ID.
• FY ended between December 2019 and April 2020: deadline between October 10th, 2020 and October 14th, depending on the taxpayer’s Tax ID.
Should you require any further information on this matter, please do not hesitate to contact us.
Santiago L. Montezanti