AMC Consulting
The landscape has changed, and that is already becoming apparent in practice.
With the update to the sanctions regime applicable as of 2026, penalties for formal non-compliance in the area of International Operations have taken on significantly greater weight. And this doesn’t only affect large Multinational Groups: it can also impact importing or exporting companies, even when they operate with independent parties.
ARCA has issued the General Resolution (GR) No. 5798/2025, which increases the thresholds applicable to Transfer Pricing (TP) obligations and updates certain formal aspects related to the filing of the Master File.
Yesterday, ARCA realeased the draft amendment to the Transfer Pricing regulations. Based on the experience gained since the current framework came into effect, the Agency proposes to refine certain criteria and scopes, which would ultimately replace General Resolutions 4717 and 5010.
The Executive Branch has published Decree 767/2025, introducing significant changes to the Income Tax regime and Transfer Pricing regulations. The decree substantially updates the reporting thresholds: the limit for filing Form F.2668 for transactions with independent parties increases from ARS 10 million to ARS 500 million, while the thresholds for reporting transactions with related parties or with non-cooperative or low-tax jurisdictions rise to ARS 150 million and ARS 15 million, respectively.
Recently, the Revenue and Customs Control Agency (ARCA) has intensified its supervision of international transactions concerning Transfer Pricing (TP) compliance. The Agency has been sending notifications to taxpayers, notifying them of potential international transactions that may be subject to TP regulations.