Transfer Pricing

Companies with transactions with related parties abroad or with parties in non-cooperative or low-tax jurisdictions, according to the thresholds in force. We analyse whether you are covered and which documentation applies.

Functional analysis, selection of the method, search for comparables and a conclusion on whether the transactions were agreed at market value, with the documentation and returns ARCA requires.

Group-level reports. The Master File describes the structure, the business and the pricing policy; the Country by Country Report shows revenue, results and taxes by country. We determine whether the group must file them in Argentina.

We defend the position during the audit with the technical support of the study, and assess advance pricing agreements when they make sense.

Yes. Management fees, royalties, loans and shared services must be documented and agreed at market value; they are the most scrutinised transactions.

We work with the group's tax team to align the global policy with the local documentation, in English if required.