Global

Details

  • Service: Tax, Global Transfer Pricing Services, International Tax
  • Type: Regulatory update
  • Date: 1/2/2014

Argentina - Tax haven jurisdictions for transfer pricing purposes 

January 2: A resolution issued by the tax administration of Argentina (AFIP) expands on the criteria for identifying jurisdictions to be included in the “white list” of countries for which the transfer pricing rules will not apply.

Resolución General 3576 (Spanish) was published in the Boletin Oficial No. 32,796 on 31 December 2013, and expands on a May 2013 decree issued by the AFIP that replaced the process for determining when countries are “tax haven” jurisdictions for transfer pricing purposes.


The May 2013 decree (Decreto 589/2013) states that the AFIP will prepare a new list of countries or territories that have signed tax information exchange agreements with Argentina and, thus, are considered as cooperating jurisdictions for purposes of tax transparency.


Accordingly, countries or territories that are not included on the white list are considered countries with low tax or no taxation—i.e., tax haven jurisdictions. The AFIP has provided the white list (Spanish) of cooperating jurisdictions.


Thus, transactions with entities not located in these countries are automatically subject to Argentina’s transfer pricing regime.


For more information, contact a tax professional with KPMG’s Global Transfer Pricing Services practice:


Marcelo Castillo

+54 11 4316 5834




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