From this agreement, AFIP will automatically receive strategic statements about how large companies operate to conduct risk analysis and Avoid potentially abusive maneuvers in transfer pricing matters, i.e. operations within the company.
Since 2016, the AFIP has leveraged a series of tools to enhance financial transparency and reliable inclusion with the goal of avoiding evasion and evasion maneuvers. Now, with the agreement implemented with the IRS, The strategic documents on transfer pricing that the VCA will access are part of the International Transparency Standards promoted Organization for Economic Cooperation and Development And the Group of Twenty.
Specifically, the agreement was introduced under Action 13 of the Action Plan Against Base Erosion and Benefit Transfer (BEPS, for its English acronym). Happy Charter establishes An annual information system to display country-specific reports on the resident issues that make up a group of multinational companies. There is a signal “To erode the tax base and divert the benefits resulting from the existence of loopholes or undesirable mechanisms between the various national tax systems that multinational corporations can use.”
It happens that although international tax regulations have been put in place to avoid the so-called double taxation, there are various maneuvers by multinational companies that tend to shift profits to locations where there is little or no real activity. This is the reason since then The OECD is working to reinforce the need to combat these practices by promoting information exchange between countries.
The reports that the AFIP will receive consist of an annual statement of multinational groups founded in the United States that operate in the country and whose combined annual total revenue at the global level is more than 750 million euros.
According to what was signed in the “individual country reports”, Argentina will receive the following information in detail: the judicial authorities in which it operates, the different entities that comprise it, the economic activities that it carries out, the number of workers, information on the distribution of income, results and taxes paid and owed that it has developed Every constituent entity of the group around the world.
The implementation of this agreement is paramount because American multinational corporations have a strong presence in our country. Indeed, although the AFIP has multiple treaties and agreements for information exchange, No such agreement has yet been reached with the United States, which is one of the most commercially important countries for Argentina.
From the body headed by Marco Del Ponte they indicated it “The tool will allow increased international tax transparency.” It also highlights that the reports improve access to data on the global distribution of income, taxes paid and some indications about the location of economic activity among the tax authorities in which these groups operate.
It should be noted that at the local level, AFIP is making progress in implementing the Tax Planning Information System, which is a tool used globally to prevent evasion and prevent money laundering. In fact, it is also a tool promoted by the OECD and the G20 so that governments can identify areas of tax risk early on, and it is already in place in European Union countries as well as in the United States, the United Kingdom, South Africa, Canada, and Mexico.