The Argentinian tax authority AFIP has published additional information on the interpretation and filing requirements of the CbC rules (country-by-country) (AFIP Resolution 4130 changed by Resolution 4332). It has amended them by answering to an Q&A on its website. The CbC implementation rules are based on the BEPS Action 13 of the OECD.
Subsidiaries of Multination Enterprises (MNE)
Subsidiaries of MNE do not have to file a local CbC report in Argentina if there is no respective International Agreement on automatically exchanging tax information or a Competent Authority Agreement in place which enables the exchange of CbC reports.