Corporate Tax News Issue 64 - November 2022

Mandatory disclosure regime suspended until end of 2022

Argentina’s tax authorities issued a resolution on 1 November 2022 that extends the suspension of the mandatory disclosure regime through 31 December. The reason given for the suspension is to allow the authorities to address concerns about the constitutionality and operation of the rules and to request input from affected stakeholders on how to make the regime more effective or whether the regime is actually necessary.

Introduced in 2020, the regime requires the reporting of domestic and cross-border arrangements that result in a tax benefit (whether in Argentina or elsewhere) if the arrangement contains specified features. Domestic arrangements must be reported by the last day of the month following the end of the tax year in which the arrangements were implemented and cross-border arrangements must be reported within 10 days of implementation.

The tax authorities suspended the reporting regime on 1 September for 60 days, which expired at the end of October. The new resolution provides for another 60-day suspension starting from 31 October through the end of the calendar year.

Alejandra Sarni