In recent years, many countries have introduced Country-by-Country (CbC) reporting requirements to increase tax transparency and combat tax avoidance by multinational corporations (MNCs). Argentina is one such country that has implemented CbC reporting rules.

The CbC reporting requirements in Argentina were introduced through the Fiscal Reform Law No. 27,430 in December 2017. The rules apply to MNCs with consolidated group revenue of more than ARS 3.5 billion (approximately USD 58 million) for fiscal years starting on or after January 1, 2016.

Under the Argentine CbC reporting rules, MNCs are required to submit a CbC report to the Argentine tax authorities within 12 months from the end of the fiscal year to which the report relates. The report must be filed electronically through the tax authorities’ website.

The CbC report must include information on the global allocation of income, taxes paid, and certain indicators of economic activity in each jurisdiction where the MNC operates. The report must also include information on the constituent entities of the MNC, their jurisdiction of tax residence, and their business activities.

In addition to the CbC report, MNCs must also file a master file and a local file with the Argentine tax authorities. The master file provides an overview of the MNC’s global business operations, while the local file provides detailed information on the MNC’s operations in Argentina.

The master file must include information on the MNC’s organizational structure, business operations, intangible assets, financing arrangements, and related-party transactions. The local file must include information on the MNC’s transfer pricing policies and transactions with related parties in Argentina.

It is important for MNCs to comply with the CbC reporting requirements in Argentina as failure to do so may result in penalties, including fines and restrictions on the ability to do business in Argentina. Furthermore, non-compliance with CbC reporting requirements in one country may trigger penalties in other countries where the MNC operates.

MNCs may face some challenges in complying with the CbC reporting requirements in Argentina. For example, MNCs with complex organizational structures and business operations may find it difficult to provide the required information in a timely and accurate manner. In addition, MNCs may need to develop new systems and processes to collect and analyze the required data.

Overall, the introduction of CbC reporting requirements in Argentina is a positive step towards increasing tax transparency and combatting tax avoidance by MNCs. The requirements provide the tax authorities with valuable information on the global operations of MNCs and help to ensure that these corporations pay their fair share of taxes in the countries where they operate. MNCs operating in Argentina should ensure they comply with the CbC reporting requirements to avoid penalties and maintain their ability to do business in the country.