Argentina: Implementing Decree for Transfer Pricing Rules

At the end of 2018, a decree concerning transfer pricing rules has been published in Argentina which outlines the corresponding law 27.430 / 2017.

Decree Measures

The specific measures of the decree are:

  • adoption of the Master File rule
  • potential usage of other than the standard transfer pricing rule method if the transaction in question concerns the transfer of valuable or immaterial assets that are not comparable transactions
  • introduction of minimum standards for filing for transfer pricing returns, Master File and Local File
  • information regarding contracts for exports with listed prices that have to be registered with the Argentinian tax authority AFIP
  • information on arm`s length price tests for import/export transactions with international intermediaries
  • outline of general criteria for arm`s length pricing test and information sources (primarily internal comparables)
  • tested party`s information must be of the respective fiscal year


Furthermore, AFIP is expected to publish more detailed guidelines soon which further clarify how to comply with transfer pricing rules in Argentina. More information on transfer pricing rules and BEPS Action 13 in Argentina can be found here.

These regulatory changes could affect your business with view to customizing or support of your ERP/SAP system. Please contact us to learn about possible necessary reactions to the changes – we are happy to assist you!