New Transfer Pricing Thresholds Regulated

The Argentine Tax Authorities (ARCA) published General Resolution 5798 in the Official Gazette on December 16, 2025, amending the transfer pricing regulatory framework to incorporate the modifications introduced through Decree 767/2025.

The new rule updates the amounts in General Resolutions 4717 and 5010, significantly raising the thresholds for compliance with formal Transfer Pricing and International Operations obligations. It also introduces other adjustments related to information submission mechanisms.

The recitals clarify that these adjustments are pertinent notwithstanding the comprehensive review process of the transfer pricing regime currently underway, which ARCA is conducting through the participative rulemaking mechanism.
 

The most relevant modifications include:

1. Establishment of new thresholds in General Resolution 4717:

• Operations with international intermediaries (art. 41): The threshold regarding operations with a foreign intermediary is raised from ARS 30,000,000 to ARS 1,500,000,000. Below this amount, the duty to maintain the intermediary’s financial statements and the certification regarding their remuneration and other transaction aspects does not apply.
• Transfer Pricing Study (art. 44) and Master File (art. 45): The threshold to require the filing of these reports is raised to ARS 150,000,000 for the aggregate amount of transactions or ARS 15,000,000 individually (previous values were ARS 3,000,000 or ARS 300,000, respectively). Regarding the Master File, the threshold for the group’s consolidated annual revenue is also raised to ARS 100,000,000,000 (previously ARS 4,000,000,000).
• Filing of Form 2668 (art. 48): the threshold to be obligated to file this form is raised from ARS 10,000,000 to ARS 500,000,000 for the annual amount of imports and exports of goods between independent parties, and to ARS 150,000,000 for the aggregate amount of transactions or ARS 15,000,000 individually (previous values were ARS 3,000,000 or ARS 300,000, respectively) for operations governed by transfer pricing rules.

2. Update of thresholds for the Simplified Regime (General Resolution 5010)

• The annual billing amount to opt for the Simplified Regime for International Operations is adjusted: in aggregate, higher than ARS 500,000,000 and less than ARS 3,000,000,000 (previously the range was ARS 10,000,000 to ARS 60,000,000).
• The threshold regarding the tax authorities' powers to request the Transfer Pricing Study from subjects who have opted for the Simplified Regime is raised to ARS 150,000,000 in aggregate or ARS 15,000,000 individually (previously ARS 3,000,000 and ARS 300,000, respectively).

3. Other Modifications

• Master File: alternative filing options are incorporated in cases where there is more than one group entity resident in Argentina.

• Digital Filing: the procedure for submitting Form 4501 is updated, and Form 2673 is established for filing the Master File.
• “No Movements” Option (Form 2668): it is established that, after two consecutive fiscal periods filing the form as “no movements,” the taxpayer will be exempted from said obligation until their situation changes.

Effective Date and Application

The provisions of General Resolution 5798 enter into force on the day of its publication (December 16, 2025) and will apply to fiscal periods ending on or after October 31, 2025, inclusive.