Introduction

The Argentine government has been concerned about international tax avoidance techniques based on transfer pricing almost since the inception of the UK-based income tax system in 1932. A central reason for this concern has been to protect the corporate income tax base in the context of the globalisation of the food industry, in which Argentina has been a key player since the beginning of the twentieth century. The two core areas on which most transfer pricing disputes have been focused in this country over the last eighty years are conduit schemes and the strategic use of intangibles.

This chapter aims to answer two main questions. First, what has been the evolutionary pattern of transfer pricing regulations in Argentina since the inception of corporate income taxation in 1932? Second, what is the core dynamic of transfer pricing dispute resolution in Argentina since then?

The first point argued in this chapter is that the evolution of the Argentine transfer pricing regulatory framework can be divided into six periods since the inception of the income tax system. Each regulatory period is normally associated with a major local fiscal debacle. One dominant feature here is the convergence of transfer pricing law with international standards. Indeed, the Argentine legal framework has been gradually evolving in order to achieve consist- ency, first with the League of Nations’ 1933 Carroll Report and then with the OECD recommendations on transfer pricing.