No significant legislative changes have been adopted to date in
direct response to the OECD's work, but the country has taken
steps to address perceived international tax avoidance through
domestic measures. Argentina's new president took office in
December 2015, and tax reform is expected, although the timing is
uncertain.
In recent years, companies in Argentina have faced increasing
audit activity from the tax authorities at all jurisdictional
levels, and international transactions are in focus. In particular,
transfer pricing and thin capitalization transactions have
attracted scrutiny. More recent tax audit activity has targeted
imports and treaty shopping.
Argentine tax authorities are becoming more inclined to
challenge tax-motivated transactions and structures on the basis of
'substance over form'. The principle is embedded in
Argentina's Tax Procedures Act, and Argentine tax authorities
apply it broadly to disregard the legal form of an arrangement
