Transfer Pricing

As well as around the world, transfer pricing is one of the priority fields of tax administration, its growing significance is proved by the dramatic increase in tax penalties from this year.

Taxpayers do not only have to pay attention to be compliant with the arm’s length principle, but they are also obliged to prepare documents in accordance with the Income Tax Law and R.G. (AFIP) 1122/01. However, transfer pricing is not only an obligation, but it is also a great opportunity for tax optimization that is worth making use of by business entities.

Mazars' advisors have years of experience in all fields of transfer pricing, including transfer pricing documentation, comments, pricing of future transactions, supporting of tax investigations and also the representation in legal cases in transfer pricing

We are at your disposal with the following services in transfer pricing:

♦ Planning

  • Well-designed pricing practices by which the chance of debates with the authorities can be lowered, double taxation can be avoided and taxation can be optimized at group level;
  • Participation in the procedures related to the determination of the arm’s length price by the tax authority, assistance, preparation of the relevant documents;
  • Mapping and management of transfer pricing risks.

♦ Preparation of transfer pricing documents

  • Revision of previously prepared documents, commenting from the point of view of Argentinean tax considerations;
  • Preparation of documents, completion and documentation of analysis according the local law;
  • Updating documents;
  • Preparation of country-specific file and master file;
  • Preparation of benchmarking analyses;
  • Preparation of documents aligned with the regulations of other countries.

♦ Settlement of disputes

  • Advising in official and court cases related to transfer pricing;
  • Representation in court cases.

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