Transfer pricing – Exceptional extension to March 2020

The dates of submission of the sworn declarations of transfer prices and international operations for the fiscal periods closed between 12/31/2018 and on 6/30/2019, both inclusive.

Through General Resolution AFIP 4560/2019 published in the Official Gazette today, the Agency has extended the expiration dates with respect to compliance obligations regarding Transfer Pricing. In particular, the annual report and affidavit (form F.2668) for fiscal years ending on 12/31/2018 until 06/30/2019 must be submitted electronically to the treasury from March 16 to 20, 2020.

Apart from the aforementioned extension, as of the tax reform of 2017 (Law 27,430), taxpayers and professionals in the field are waiting for the regulation that gives light and certainty to the obligations and particularities of the regime, as well as of the content of the report and annual affidavit F.2668. At the moment, only the reform project circulated by the Agency is known, which has expanded several aspects of compliance and documentation to be preserved and presented, as well as attempted to adapt to international standards in this area. The norm mentioned in the previous paragraph has not given any precision regarding the new regulation, and has only focused on establishing this new extension, so the prompt sanction of a new general resolution establishing such definitions is expected, on which We will keep you informed as soon as it is published.