Branch Report on Argentina
Cahiers de Droit Fiscal International, Volume 102 B: The Future of Transfer Pricing, 91-110, International Fiscal Association, 2017 Rio de Janeiro Congress.
Posted: 14 Sep 2017
Date Written: August 29, 2017
The evolution of the Argentine international tax system illustrates the impact of globalization on tax convergence in the first nearly hundred years of corporate income taxation in this G20 country. A representative example is the gradual convergence with international standards in the area of transfer pricing (TP). Indeed, the Argentine domestic legal framework has evolved to achieve greater consistency, first with the League of Nations 1933 Carroll Report and then with the 1995 version of the OECD guidelines. This convergence was reinforced by the implementation of the arm’s length standard (ALP) in the Argentine tax treaty network in 1966. The ALP later permeated Argentine domestic law as of 1998, when the foreign direct investment (FDI) flow, as a percentage of GDP, was at its highest since the 1911–1915 period. In this convergence, the OECD guidelines are increasingly playing a crucial role, as Congress and the courts have gradually been transplanting them into domestic law since 1998. The main role of the ALP, as applied by the Argentine tax authorities, is to protect the corporate income tax base. This deeply rooted convergence path with the global standard is expected to be in place in relation to the 2015 version of the OECD guidelines crystallized in the base erosion and income shifting (BEPS) reports. The policy objective of the Argentine government of joining the OECD within the next few years should further reinforce this convergence path.
Keywords: Transfer tricing, emerging world, trends
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