The Annex II of General Resolution No. 4130 of Argentina establishes the country-by-country report model that reporting entities of Multinational Enterprise Groups (MNEs) must follow to comply with their reporting obligations. This model provides the structure and specific fields that must be completed, including information such as:

Identification of the reporting entity and the multinational group. Details of the jurisdictions in which the MNE group operates. Financial information, including total revenues, results before taxes, taxes paid and accrued, share capital, undistributed accumulated earnings, number of employees, and tangible assets. Details of each member entity of the MNE group, including its tax identification, name, tax jurisdiction and country of incorporation, primary economic activities, among others.

This annex provides a standardized format to ensure consistency in the presentation of country-by-country information and facilitate its exchange among tax authorities from different jurisdictions.

COUNTRY-BY-COUNTRY REPORT PREPARATION IN ARGENTINA

The following considerations must be taken into account:

1. The fiscal year to be reported in the country-by-country report should cover the fiscal year of the ultimate parent entity of the MNE Group. To this end, the MNE Group may choose between: a) Reporting the information of its constituent entities for the fiscal year ending on the same date as that of the ultimate parent entity, or which ended within the TWELVE (12) months prior to that date. b) Reporting the information that has been reported by all constituent entities for the same fiscal year of the ultimate parent entity.
2. The contained information will be provided in a single denomination currency – US Dollar (U$S), Argentine Pesos ($), or Euros (€) – at the option of the reporting entity, and in a single language – Spanish.
3. The reporting entity of an MNE Group will systematically use the same data source, period after period, to complete the country-by-country report. It may choose to select as information sources the consolidated financial statements, the individual financial statements of each entity, the financial statements for regulatory purposes, or information from its internal management systems. If the financial statements are used as the basis for the preparation of the report, all amounts will be converted to the functional currency declared by the MNE Group at the average exchange rate of the fiscal year to be reported. This selection must be reported in Section 3 of Section A of this annex. The reporting entity will provide a detailed description of the data sources used in Section 3 of Section A of this annex. If any changes are made to the data source used, the reasons for the change and its consequences must be explained.
4. An entity, whose capital or corporate control corresponds to more than one unrelated MNE Group, will be considered as a constituent entity of each of the groups, as long as the accounting principles and standards applicable to each group, separately, require the consolidation of its information in the respective consolidated financial statements.
5. If there is more than one constituent entity of an MNE Group in a tax jurisdiction, the information to be reported in Section 1 of Section A of this annex will be produced on an aggregated basis at the jurisdictional level, regardless of whether the transactions took place across borders or within the jurisdiction, or between related and unrelated parties.

The specifications outlined below must be considered in order to complete the information to be included in the various sections of Section A of this annex:

Section 1:

a) Tax Jurisdiction:

i) All jurisdictions where each entity belonging to the MNE Group is tax resident must be identified, regardless of the size of business operations conducted in those jurisdictions.

ii) When an entity belongs to multiple tax jurisdictions, the determining criterion of the applicable tax treaty shall be applied to determine the tax residency jurisdiction. In the absence of an applicable tax treaty, the entity shall be assigned to the tax jurisdiction of its effective management location.

iii) All MNE Group entities that the reporting entity considers not tax resident in any jurisdiction shall be listed separately.

iv) All jurisdictions whose legislation governs the organization or incorporation of each named entity shall be identified if different from the tax jurisdiction.

v) Data relating to permanent establishments shall be reported with reference to the tax jurisdiction where they are located, not to the tax jurisdiction of residence of the business unit to which the permanent establishment belongs, which must also be identified. The information presented in the tax jurisdiction regarding the business unit to which the permanent establishment belongs shall exclude financial data related to the permanent establishment.

b) Revenues:

Revenues shall include proceeds from sales of inventory and properties, services, royalties, interest, premiums, and any other concept, including extraordinary revenues and gains, as included in the consolidated financial statements prepared in accordance with applicable accounting principles, excluding amounts received from other group entities as dividends, as follows:

i) Total revenues of all MNE Group entities in the relevant jurisdiction generated from transactions with related parties, ii) total revenues of all MNE Group entities in the relevant jurisdiction generated from transactions with unrelated third parties, and

iii) total of the amounts referred to in the preceding points (i) and (ii) for each jurisdiction.

c) Profit (Loss) before corporate income tax (income tax):

This comprises the sum of profits (losses) before applying corporate income tax for all tax-resident Group Entities in the corresponding tax jurisdiction, including extraordinary items of income and expenses.

d) Corporate income tax (income tax) paid:

This should reflect the total amount of corporate income tax (income tax) actually paid during the fiscal year to be reported by all entities resident in each tax jurisdiction and in any other tax jurisdictions, including, among others:

i) advance payments meeting the tax liability for the fiscal year to be reported and for previous year(s),

ii) tax withholdings made by other parties with respect to payments to such group entities, and

iii) payments made under protest, net of amounts refunded during the fiscal year to be reported.Advance payments on account of the tax liability for the fiscal year to be reported or for previous years that are refunded shall be deducted from the corporate income tax (income tax) paid and detailed in Section 3.

e) Corporate tax (on earnings / on income) accrued: The sum of expenses accrued for the aforementioned tax during the fiscal year to be reported by all resident entities in the corresponding tax jurisdiction must be indicated. These expenses will only reflect the transactions of the current fiscal year and will not include deferred taxes or provisions for uncertain tax liabilities, regardless of whether payments were made regarding them.

f) Declared capital: Under this column, the sum of declared capital of all resident entities in the corresponding tax jurisdiction must be stated. As for permanent establishments, the declared capital will be communicated by the legal entity to which the permanent establishment belongs, unless there is a specific capital requirement for regulatory purposes in the tax jurisdiction of such establishment.

g) Undistributed accumulated results: The total sum of undistributed results at the close of the fiscal year of all resident entities in the corresponding tax jurisdiction must be detailed, and they must be separately detailed in Section 3. In relation to permanent establishments, the undistributed results will be communicated by the legal entity to which the permanent establishment belongs.

h) Number of employees: The total number of full-time equivalent employees of all resident entities in the corresponding jurisdiction must be communicated. This information:

i) May refer to the end of the fiscal year to be reported, based on the average employment levels for the fiscal year or using any other consistently applied reference across all jurisdictions and from year to year,

ii) may include independent contractors participating in the ordinary operating activities of each Entity, and

iii) will allow for rounding or reasonable approximation of the number of employees, provided that it does not substantially distort the relative distribution of workers among different jurisdictions.

i) Tangible assets other than cash and cash equivalents: The sum of the net book values of tangible assets of all resident entities in the relevant jurisdiction must be indicated. Regarding permanent establishments, assets will be communicated by reference to the tax jurisdiction where the establishment is located. Tangible assets, for this purpose, do not include cash or cash equivalents, intangible assets, or financial assets.

j) Main economic activity or activities: The nature of the main economic activity or activities carried out by each member entity in the relevant tax jurisdiction must be determined, by checking the corresponding box or boxes.

Section 2:

Regarding each tax jurisdiction in which the MNE Group participates, the following is requested: a) Prepare a list of all member entities of the MNE Group with their names or legal names. b) Provide information on the jurisdiction under whose laws each member entity is incorporated or organized, if different from the tax jurisdiction. c) Identify the main business activities carried out by each member entity.

Section 3:

In this section, any additional information or explanation necessary for the proper interpretation of the information provided in the form will be provided.