Following the update of the thresholds applicable to the Information Regime for International Transactions and Transfer Pricing (TP), Form F.2668 has gained renewed relevance for taxpayers subject to the regime. In particular, the questionnaire included in Form F.2668 (the annual – return filed by taxpayers subject to the regime) has been expanded and reoriented towards a fiscal risk management approach, which means that, in practice, it may operate as a risk profiling tool for ARCA.

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.