Argentina: “White list” countries for 2016; transfer pricing implications
The Argentine tax authorities (AFIP) posted an updated “white list” of countries, jurisdictions, and territories—that is, a list of countries and jurisdictions that are identified as cooperative for tax transparency purposes. A broader application of Argentina’s transfer pricing rules will not apply to transactions involving entities located in the countries and jurisdictions identified on the “white list.”
Decreto No. 589/2013 (May 2013) established the process for determining when countries are considered to be “tax haven” jurisdictions for purposes of a broader application of Argentina’s transfer pricing rules.
The 2016 “white list” (Spanish) of cooperating jurisdictions identifies countries and territories that have signed tax information exchange agreements with Argentina and, thus, are considered as cooperating jurisdictions for purposes of tax transparency. The updated “white list” is effective 1 January 2016.
Conversely, countries or territories that are not included on the “white list” are considered countries with low tax or no taxation—i.e., tax haven jurisdictions. Thus, transactions with entities located in these countries are subject to Argentina’s transfer pricing regime.
