The Argentine Tax Authorities issued Resolution 4838/2020 on October 19, which follows BEPS Action 12 (Mandatory Disclosure Rules). The resolution, effective as of October 20, creates an informative regime with respect to domestic and international tax planning strategies. The new reporting requirements may apply retroactively.
While numerous OECD jurisdictions have enacted similar disclosure rules, the Argentine Regime appears to broaden the scope to domestic planning and does not appear to be limited to ‘aggressive’ planning.
Argentine taxpayers should continue to monitor for further clarification and developments regarding covered situations and transactions. Taxpayers should evaluate existing and new structuring involving Argentina to determine whether they are subject to the new requirements.