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The Technical Transfer Pricing Study is regulated

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The SET (Subsecretaría de Estado de Tributación – Undersecretariat of State for Taxation) has issued General Resolution No. 115/2022, which regulates the Technical Transfer Pricing Study (TTPS) and specifies the form, terms, and conditions for its presentation.

Exceptional measure

It was provided, as an exceptional measure, that taxpayers with fiscal year-end as of April 30, 2021, and December 31, 2021, may file the obligation related to the TTPS until October 31, 2022, without incurring a violation for contravention.

Likewise, such a report may be submitted until the indicated date in digital format through the SET’s Desk of Parties. On the other hand, taxpayers with fiscal year-end as of April 30, 2022, and June 30, 2022, may file the ETPT corresponding to fiscal year 202, also in digital format, within the ordinary deadlines established in article 9 of the Resolution.

Other transitory measures

The Resolution establishes that the evidentiary documents that disprove the presumptive link with foreign residents, corresponding to the operations carried out in fiscal years 2021 and 2022, by taxpayers with fiscal year-end as of April 30, 2021, June 30, 2021, December 31, 2021, April 30, 2022, and June 30, 2022, must be submitted to the SET’s Registration Office in portable document format, according to the following calendar:

Fiscal year-end of the CIT taxpayerFiling month
April 30, 2021
June 30, 2021
December 31, 2021
May 2022
April 30, 2022July 2022
June 30, 2022Septemeber 2022
Source: SET 12/04/22

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