ARCA has updated Argentina’s International Transactions and Transfer Pricing (TP) regime through General Resolution (GR) 5903/2026, which replaces General Resolutions 4717 and 5010 and their amendments. In addition to raising filing thresholds, the GR introduces simplification options and further guidance on the economic analysis and documentation of international transactions within its scope.
The GR entered into force on 30 September 2026 and applies to fiscal years beginning on or after 1 October 2026. For companies whose fiscal year ends on 31 December, the first fiscal year covered will be 2027.
- Higher filing thresholds
- Annual Information Return (Form F.2668) for transactions subject to TP rules: the aggregate threshold increases from ARS 150 million to ARS 1.5 billion, while the individual transaction threshold increases from ARS 15 million to ARS 300 million.
- TP Study: the general thresholds increase from ARS 150 million to ARS 3 billion in aggregate and from ARS 15 million to ARS 600 million per transaction.
- Master File: the group’s annual consolidated revenue threshold increases from ARS 100 billion to ARS 500 billion for the fiscal year preceding submission. Transactions with foreign related parties must also exceed ARS 3 billion in aggregate or ARS 600 million per transaction.
- 2668 of international transactions, for imports and exports of goods with independent parties: the annual threshold increases from ARS 500 million to ARS 7.5 billion.
- A specific rule has been introduced for Argentine companies belonging to multinational enterprise groups required to file a Country-by-Country Report under General Resolution 4130: these companies must file the Transfer Pricing Study where their transactions subject to TP rules exceed ARS 1.5 billion in aggregate or ARS 300 million per transaction, i.e., the thresholds applicable to Form F.2668.
Once any of the Form F.2668 filing thresholds is exceeded, both imports and exports of goods with independent parties, and transactions subject to TP rules must be reported in Form F.2668, even where one of these categories does not exceed its own threshold.
Other relevant developments:
- Selection of a foreign tested party
A foreign entity may be selected as the tested party for specified transactions and methods where its functions, assets and risks are less complex and the information and comparability requirements prescribed by the GR are met.
- Low value-adding intragroup services
An optional simplified approach is introduced, removing the requirement to perform a comparability analysis for certain low value-adding intragroup services. To qualify, the markup on operating costs and expenses must be at least 5% where the service provider is an Argentine entity, or no more than 5% where the provider is a foreign related party.
The total amount of such services received must not exceed 10% of the Argentine entity’s operating expenses; for services provided, the materiality threshold is 10% of its operating revenue. The benefit derived or expected to be derived from the services must be substantiated. Where the tested party is the Argentine entity, it must not incur operating losses or be undergoing a business restructuring.
- Express recognition of hard-to-value intangibles
The GR identifies intangibles for which comparables are unavailable or whose estimates or cash flow projections are subject to significant uncertainty during development. For their assessment, it refers to other valuation methods and techniques.
- Further guidance on supporting the economic analysis
The GR specifies when losses incurred by comparables are considered recurrent and addresses their treatment, together with cases involving insolvency or bankruptcy proceedings. Changes in methods, profit level indicators or comparables between fiscal years must also be substantiated, and the express requirements for reconciling segmented financial information are expanded.
- Intragroup financing and implicit support
The circumstances in which the group’s credit rating may be used are more narrowly defined: it may be applied where implicit support prevents the identification of reliable market interest rates for the borrower on a standalone basis. The TP Study must substantiate the credit rating used and its impact on the pricing of the financing transaction.
- Specific rules for exports of commodities with quoted prices
The GR implements the use of official FOB values as minimum values for certain agricultural exports.
It also introduces guidance for sales or supply contracts in extractive industries, requiring projected business profitability to be substantiated and providing for the application of the comparable uncontrolled price method.
- Master File submission in English
The Master File may be submitted in Spanish or English. Where it is submitted in English, a Spanish translation must be made available upon ARCA’s request.
- Transfer pricing adjustments
The resolution expressly states that TP adjustments cannot be used to reduce taxable income reported in Argentina. An exception applies to adjustments arising from a mutual agreement procedure between tax authorities under a double tax treaty.
- Eligibility requirements for the Simplified Regime
For imports and exports of goods with independent parties, the qualifying range becomes more than ARS 7.5 billion and less than ARS 45 billion, subject to the regime’s exclusions.
The requirement concerning losses is also tightened for the eligibility routes based on turnover or the proportion of related-party transactions: the absence of recurrent losses is no longer sufficient. The company must not report accounting losses in the fiscal year being reported or in either of the two preceding fiscal years.
- New filing deadlines and CPI indexation
The Transfer Pricing Study, Form F.2668 and Simplified Regime Form F.2672 will be due between the 2nd and 6th days of the seventh month following fiscal year-end, depending on the final digit of the taxpayer’s Argentine Tax Identification Number (CUIT), with adjustments for non-business days.
Thresholds subject to annual Consumer Price Index (CPI) indexation will first be adjusted for fiscal years beginning on or after 1 January 2028.
Although these changes and the new thresholds may reduce certain filing obligations, transactions must still comply with the arm’s length principle. Businesses should therefore assess how the changes affect their obligations and maintain the documentation needed to support their transactions.
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