AMC Consulting
We advise companies in all kinds of projects, including preparing Supporting Documentation (Local Files), designing Transfer Pricing Policies, analyzing financial transactions, valuing intangible assets, benchmarking, and business restructuring, among others.
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Transfer Pricing in Argentina
Our practice covers Transfer Pricing compliance and consulting for all Latin American countries and Spain, supported by a specialized team with over 20 years of experience. We offer an integrated service that oversees the entire process until filing in every jurisdiction.
We lead regional projects across all Latin American countries where our clients operate. Having a centralized team allows our clients to achieve economies of scale, maintain uniform criteria in their economic analyses, streamline communication, facilitate project monitoring, and minimize the production and circulation of information. This makes working with Advice for Mutinational Companies (AMC®) the best cost-effective decision.
We are a boutique consulting firm that exclusively serves companies engaged in international transactions. Our strong training program and high-quality standards are designed to exceed our clients' expectations in every deliverable.
Recently, the Revenue and Customs Control Agency (ARCA) has intensified its supervision of international transactions concerning Transfer Pricing (TP) compliance. The Agency has been sending notifications to taxpayers, notifying them of potential international transactions that may be subject to TP regulations.
On June 18, 2021, was published in the Official Gazette the Federal Administration of Public Revenues (“AFIP“) General Resolution 5010/2021 (“RG 5010“), applicable to fiscal years ending on December 31, 2020 and thereafter, the main purpose of which is to establish the implementation of a Simplified Regime for International Transactions (“Simplified Regime”), and to extend for 3 (three) months the Transfer Pricing (“TP”) filing due dates, moving them to the end of next September.
Argentina is adapting its Transfer Pricing and related Information Regimes to international standards, mainly based on the document issued by the Organization for Economic Cooperation and Development (“OECD”) in 2015, which details an exhaustive action plan to prevent base erosion and profit shifting, known as “BEPS”.
In 2017, through Law 27.430, amendments were introduced in the Income Tax Law (ITL) (Decree 824/19). Among these amendments, article 20 was incorporated, providing the following: “For all purposes provided for in this law, any reference to “jurisdictions with low or null taxation” shall be understood as referring to those countries, domains, jurisdictions, territories, associated states or special tax regimes that establish a maximum income tax rate of less than sixty percent (60%) of the rate referred to in article 73 (a) of this Law.” The rate referred to in article 73 of the ITL is 25%. At the…
Rivadavia Av. 5908 | 11 Floor | Office C (C1406GLP)
Autonomous City of Buenos Aires
Ph.: +54 11 5263 7374
info@amcconsulting.com.ar