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On Sep 20, 2017 the National Tax Bureau issued General
Resolution E- 4130/2017 (the "Resolution") within the
framework of action 13 of the project Base Erosion and Profits
Shifting ("BEPS") launched by the OECD and the G20.
The new Resolution provides for an annual informative regime
comprising the filing of a country-by-country report to entities
members of a Multinational Entities ("MNE") Group. It
excludes from the informative regime those entities which belong to
a MNE Group but which total consolidated income for the economic
period prior to the economic period of the report, does not exceed
Euro 750 MM, or its equivalent in the local currency of the
Ultimate Parent Entity at the exchange rate applicable as of
January 31st, 2015.
Reporting Taxpayer
Filing is required to:
1) MNE Groups when the Ultimate Parent Entity is resident in
Argentine for fiscal purposes;
2) The Argentine entity that has been appointed – by its
Ultimate Parent Entity – to stand in as responsible for the
filing. The appointment is effective only if the Argentine
entity's net worth amounts to AR$ 50 MM or higher, or if it has
operative/functional structure that allows it to gather information
for the filing of country-by-country report.
3) any entity of Argentina member of the MNE Group, not included
above, if:
(i) the Ultimate Parent Entity is not subject to filing
country-by-country report under its fiscal jurisdiction,
(ii) the jurisdiction of the Ultimate Parent Entity has not
entered into a Competent Authority Agreement to which Argentina is
a party at the due date for submitting the country-by-country
report, even when it may be party of an International Agreement in
force with Argentina; or
(iii) there are certain systematic failures in complying with
the automatic exchange information by the jurisdiction of the
Ultimate Parent Entity.
It also provides for an informative regime (local report)
applicable to all entities resident in Argentina that belong to a
Group of MNE, who must grant information regarding their Ultimate
Parent Entity and of the entity submitting the country-by-country
report of the Group to which they belong.
The Resolution provides for the confidential treatment the
National Tax Bureau must give to the information obtained under the
country-by-country report. It also sets forth the fines for the
lack of compliance with the regime.
The Resolution entered into effect as from the date of its
publications in the Official Gazette (Sep 20, 2017) and it
encompasses the fiscal year of each Ultimate Parent Entity of the
MNE Group starting as from January 1st, 2017
inclusive.
P>The content of this article is intended to provide a
general guide to the subject matter. Specialist advice should be
sought about your specific circumstances.
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