The changes, introduced by General Resolution 5798/2025, update local file, master file and simplified regime requirements in line with current economic conditions and apply from fiscal periods ending on or after 31 October 2025.

RF Report

Argentina’s Federal Tax Administration (ARCA) has increased the revenue thresholds that trigger mandatory transfer pricing documentation, aiming to streamline reporting requirements for multinational and local taxpayers.

The changes are set out in General Resolution 5798/2025, published in the Official Gazette on 16 December 2025.

Reporting Type Previous Threshold New Threshold Notes
International intermediaries (Article 41, RG 4717) ARS 30 million ARS 1,500 million Submission of financial statements and other documentation is required only above this value.
Local File & Form 2668 (Article 44) – Aggregate transactions ARS 3 million ARS 150 million Applies to transactions with related parties and entities in low-tax or non-cooperative jurisdictions.
Local File & Form 2668 – Individual transactions ARS 300,000 ARS 15 million Applies to transactions with related parties and entities in low-tax or non-cooperative jurisdictions.
Master File (Form 2673, Article 45) – Group revenue ARS 4 billion ARS 100 billion Required if group revenue exceeds threshold and foreign related-party transactions exceed thresholds below.
Master File – Aggregate foreign related-party transactions ARS 3 million ARS 150 million Individual transactions threshold increased from ARS 300,000 to ARS 15 million.
Simplified regime (Form 2672, RG 5010) ARS 60 million ARS 500 million – 3 billion Form 2672 may replace transfer pricing study; full study is required if transactions exceed ARS 150 million or ARS 15 million individually based on market or risk conditions.

Under the updated rules, entities belonging to multinational groups must submit a Master Report (Form 2673) if the total consolidated revenue of the group exceeded ARS 100 billion in the previous fiscal year and transactions with foreign related parties exceed ARS 150 million in aggregate or ARS 15 million individually. Taxpayers who have no changes from prior Master Reports may submit a ratification note instead of a full report, simplifying compliance.

All filings must be submitted digitally through ARCA’s web portal using Clave Fiscal, and documentation must include professional certifications, digital signatures, and certified Spanish translations when the original documents are in a foreign language. General Resolution 5798 updates previous frameworks established under General Resolutions 4717 and 5010, reflecting current economic conditions and clarifying the reporting obligations for cross-border and related-party transactions.

These changes apply to fiscal periods ending on or after 31 October 2025.