Implements a new mandatory disclosure regime for international transactions
27 Dec 2022
On December 27, 2022, the Federal Tax Authority of Argentina (FTA) issued a resolution in the Official Gazette, introducing the International Comprehensive Information Reporting Regime (RICOI). RICOI imposes compliance requirements on a range of entities, including companies, non-profit organizations, trusts, mutual funds, and permanent establishments incorporated or located in Argentina. The reporting obligations encompass:
Transactions conducted by Argentine legal entities with parties situated in non-cooperating jurisdictions or low/no-tax jurisdictions, even if these transactions occur through their permanent establishments abroad.
Transactions with related parties domiciled abroad, which includes legal entities, trusts, permanent establishments, or other entities, particularly business restructurings that fall outside the scope of the international information regime of country-by-country reporting.
The primary objective of this framework is to enhance the effectiveness and efficiency of assessing compliance risks in international taxation matters. The reporting deadline aligns with the due date for filing income tax returns. Failure to comply with RICOI obligations will result in formal penalties in accordance with the Tax Procedure Law. These regulations, effective as of December 27, 2022, apply to information filings for fiscal years ending on or after August 1, 2022.
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Treatment and operation (Capital transfer and FOREX)
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Treatment and operation (Capital transfer and FOREX)
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