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.
Today, if a company carries out imports and/or exports of goods with independent parties and exceeds the applicable threshold (ARS 500 million annually), it is required to file Form F.2668 — and failure to do so can result in a fine of ARS 10 million. If the transactions involve related parties or counterparties located in non-cooperative jurisdictions or those with low or zero taxation, the exposure increases: in those cases, the penalty for failing to file the F.2668 rises to ARS 22 million. Furthermore, where a Transfer Pricing Study is required, the sanctions associated with that non-compliance can escalate up to ARS 35 million.
There is also a point that often goes unnoticed: the risk does not depend solely on the transaction amount, but also on who the counterparty is — even when it is an independent party. This is where certain jurisdictions may come as a surprise: for example, Paraguay, Bolivia, or certain Swiss cantons are subject to Transfer Pricing regulations in terms similar to those applicable to transactions with related parties.
In other words, monitoring transaction volumes alone is no longer enough. It is also necessary to review the structure, the counterparty, and the type of obligation that may arise in each case.
As a result, matters that many companies used to address close to the deadline — or simply overlooked — now require considerably more advance planning, internal coordination, and risk assessment.
In this new environment, getting international compliance in order on time is no longer just a technical matter. It is also a concrete way to avoid unnecessary contingencies. For further information, the penalties applicable under both regimes are attached, along with those for failure to respond to information requests and reporting regimes for Multinational Groups.