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.
The decree also redefines the concept of the “tested party,” expands the definition of “commodities with publicly quoted prices,” and grants ARCA the authority to set the deadlines for registering contracts related to the export of those commodities and to establish minimum reference indices or prices in transparent markets for exports of goods falling under specific tariff classifications.
Additionally, the regulation enables the possibility of extending the simplified income tax regime for individuals to foreign-source income, as determined by ARCA.
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