Transfer pricing in Argentina

Since 1943, Argentina has had transfer pricing rules based on the international standards in the OECD Transfer Pricing Guidelines. After explaining the historical background, this article describes the main aspects of Argentina's transfer pricing system, including the concept of associated enterprises; the transfer pricing methods and comparability criteria; the rules applicable to commodities transactions, intangible property transactions and intercompany services; the burden of proof, documentation requirements and administrative procedures; and penalties.