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.
Regarding the changes in thresholds, these are established in line with Decree No. 767/2025, significantly increasing the amounts from which taxpayers are subject to TP and international transactions regime, as well as introducing specific formal amendments regarding the Master File filing requirements. In particular:
- Transactions with independent foreign parties:
-The threshold has increased from ARS 10,000,000 to ARS 500,000,000.
- Transactions with related foreign parties and/or entities located in non-cooperative or low- or no-tax jurisdictions:
-From ARS 300,000 to ARS 15,000,000 on individual transaction basis, and
-From ARS 3,000,000 to ARS 150,000,000 on an aggregate basis.
- Documentation related to international intermediaries:
-The threshold has increased from ARS 30,000,000 to ARS 1,500,000,000.
The GR redefines the requirements for filing the Master File, establishing that the obligation applies only where both of the following conditions are met:
- The multinational group’s consolidated annual revenues exceed ARS 100,000,000,000 in the fiscal year preceding the filing; and
- Transactions with related foreign parties exceed, during the fiscal year:
-ARS 150,000,000 on an aggregate basis, or
-ARS 15,000,000 per individual transaction.
Furthermore, the Resolution establishes a new procedure for the filing of the Master File, which must be submitted through the “Tax Returns and Payments Filing” service, as an attachment to Tax Return Form F. 2673.
In addition, where more than one entity belonging to the same Multinational Enterprise Group is resident in Argentina, a single reporting entity may be designated for purposes of filing the Master File.
The provisions enter into force as from their publication in the Official Gazette and apply to fiscal years closed as from October 31, 2025, inclusive.
At AMC we remain available to assist in determining the obligations arising under the Resolution and in ensuring compliance with the new Transfer Pricing requirements.