On January 2, 2026, the Tax Innocence Law — Law No. 27,799 — was published in the Official Gazette, a significant reform to the Argentine tax system that introduces profound changes in taxpayers’ formal obligations and penalties for non-compliance. Although the reform covers multiple aspects of tax law, one of its most relevant impacts at the international level relates to the obligation to submit information related to transfer pricing, especially in the context of international tax transparency, such as the Country-by-Country Report (CbCR) for multinational groups.
What does the Tax Innocence Law establish?
Law 27,799 modifies various articles of the Tax Procedure Law No. 11,683, strengthening the tools for control and the mechanisms for formal compliance. Among its main focuses are:
- Strengthening the reporting obligations for taxpayers, especially with regard to international operations and multinational groups.
- Substantially increasing penalties for omission, inaccuracy, late filing, or incomplete information in returns and ancillary obligations.
- Establishing a penalty scheme that includes fines proportional to the turnover or value of the corresponding transactions.
These changes seek to improve the quality of information received by tax authorities and, in particular, to protect the fairness of the tax system from practices that can distort the tax base, such as those related to intra-group transactions.
Relationship with transfer pricing and international tax transparency
One of the areas that has generated the most attention within the tax community is the impact that Law 27,799 has on international reporting obligations, including:
Country-by-Country Report (CbCR)
The Country-by-Country Report is a report that multinational groups must submit when they exceed certain thresholds of consolidated global income. It contains aggregate information on income, profits, assets, and tax payments by jurisdiction and is a key part of the OECD’s tax transparency framework and the BEPS Plan.
The reform established by the Tax Innocence Law increases penalties for failure to file or incorrect filing of the CbCR, which means that multinational groups with operations in Argentina must be especially careful about the quality and timeliness of the information they submit.
Controlled transaction information
The inclusion of information related to controlled transactions—that is, transactions between related parties that may have an impact on transfer pricing—also becomes more demanding. The new law reinforces the need for this information to be complete, accurate, and submitted within the established deadlines, as failure to comply can trigger penalties proportional to the value of the transactions involved.
Stronger penalties for non-compliance
Law 27,799 incorporates a more severe penalty scheme for cases in which the taxpayer:
- Omits relevant information in their reporting obligations, including those related to transfer pricing or CbCR.
- Submits incomplete or inaccurate information.
- Fail to submit documentation in a timely manner.
These penalties may include:
- Fines proportional to the taxpayer’s gross revenue for fiscal periods.
- Fines based on the value of the transaction in question or on the consolidated revenue of the multinational group.
- Penalties for obstruction of inspection when requests for information are denied or delayed during audit procedures.
This punitive approach seeks to encourage both the accuracy and timeliness of information submitted to the Federal Public Revenue Administration (AFIP), raising the standard of formal compliance in the country.
Implications for multinational groups
The reform means that multinational groups with an operational presence in Argentina:
- Must carefully review their processes for preparing and submitting CbCR and other international information.
- Strengthen their internal controls to ensure that the data reported is complete and consistent with transfer pricing documentation.
- Take proactive measures to avoid penalties that can have a significant economic and reputational impact.
Conclusion
The Tax Innocence Law No. 27,799 represents an important regulatory evolution in Argentina, not only because of the update to the penalty regime, but also because of the emphasis it places on international tax transparency and the quality of taxpayers’ reporting obligations. For multinational groups, especially those subject to transfer pricing and CbCR rules, this reform requires a detailed review of their compliance obligations and processes.
Given the relevance of these obligations for international tax management and risk mitigation, it is advisable for affected companies to consider a preventive assessment of their reporting and documentation practices to ensure compliance with the new requirements of Argentine legislation.
Specialized advice on tax regulatory changes
In the face of tax reforms that directly impact taxpayer audit and defense processes, having a company specializing in transfer pricing is key to mitigating risks and ensuring regulatory compliance. At TPC Group, we assist companies and economic groups in the analysis, adaptation, and technical documentation required by tax authorities, providing solid solutions that are aligned with current regulations.
Source: GOB.AR