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🇦🇷 Argentina’s Audit Earthquake: From Challenge to Settlement

August 21, 2025

Extended Background

Economic volatility means Argentine authorities routinely target large corporates for audit, with compliance focused on negotiation rather than drawn-out litigation. MNEs often preferred settling, seeking certainty in an uncertain legal and economic environment.

Detailed Arguments

Taxpayer

  • Relied on thorough, OECD-aligned documentation to justify tested outcomes but was open to negotiation to minimize risk.

Revenue

  • Used the pressure of costly, protracted audits to drive speedy, tailored settlements.

Outcome

  • Most cases were resolved via confidential, multi-million-dollar settlements; rare for cases to set strict legal precedent.

Procedural Journey

  • Broad “sweep” audits prompted waves of settlement discussions; very few matters tested in higher courts.

Implications Beyond the Case

  • Risk management and high-quality documentation give MNEs crucial leverage in negotiations; certainty may trump a full legal fight in some markets.

Original Case Link:

International Tax Review
Editorial Note:

Official judgments are always best linked to directly from court or sovereign government sites (PDFs or HTML), or through leading law firm/academic sources with appropriate commentary and official citations. Cases without direct links either are not fully published due to confidentiality or are referred to trusted legal commentaries.

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