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Argentina Clarifies No Local CbC Report Filing Requirement for Constituent Entities of US MNEs for 2017 Reporting Fiscal Year

14 December 2018

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Treaty Development

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Argentina-United States

Argentina's tax authority (AFIP) has updated its Country-by-Country (CbC) reporting FAQs to include a question on whether constituent entities in Argentina of U.S. MNEs have a local CbC reporting filing obligation in respect of the 2017 reporting fiscal year. The answer provides that a local constituent entity is not required to submit a CbC report in respect of the 2017 reporting fiscal year mainly because there is no international agreement between Argentina and the United States providing for the automatic exchange of information that is in force for 2017. Note, however, that for the 2018 reporting fiscal year, an agreement...