Argentina: ARCA overhauls international tax, transfer pricing rules

Argentina’s tax authority has introduced a unified international tax and transfer pricing framework, raising reporting thresholds, revising filing requirements, and introducing new rules for tested-party selection, downward adjustments, and low-value-added services.

Argentina’s tax authority (ARCA) has published General Resolution 5903/2026 in the Official Gazette on 30 September 2026. This regulation completely overhauls and unifies Argentina’s international tax and transfer pricing rules into a single, cohesive text, formally abrogating and replacing former General Resolutions 4717 and 5010.

The new resolution folds three previously distinct compliance and regulatory pillars into one framework:

1. Core transfer pricing valuation & evaluation rules: Substantive guidelines for analysing cross-border transactions, intra-group services, intangibles, financial operations, intermediaries, and business restructurings.
2. International transaction reporting regime: Compliance rules for the annual information return (Form F. 2668), the Local File / Transfer Pricing Study (Form F. 4501), and the Master File / Informe Maestro (Form F. 2673).
3. Simplified international transactions regime: A streamlined compliance pathway (Form F. 2672) designed to reduce administrative burdens for small and medium-sized enterprises (SMEs) and lower-risk taxpayers.

The key structural provisions under General Resolution 5903/2026 are as follows:

Sharply increased reporting thresholds

ARCA significantly raised the monetary limits triggering documentation and filing obligations:

• Mandatory CbC exception: Multinational group members required to file Form F. 2668 that belong to MNE groups subject to Country-by-Country (CbC) reporting under RG 4,130 must file the Transfer Pricing Study (Form F. 4501) regardless of monetary thresholds.
• Automatic inflation adjustment: Beginning with fiscal years starting on or after 1 January 2028, all statutory monetary thresholds will automatically adjust annually based on the Consumer Price Index (IPC) published by INDEC for October of the preceding year relative to October 2026.

Statutory filing deadlines

Filing dates are aligned relative to the taxpayer’s fiscal year-end and CUIT ending digit:

• 7th month post fiscal year-end: Form F. 2668, Transfer Pricing Study (Form F. 4501), and Form F. 2672 (Simplified Regime) are due between the 2nd and 6th calendar day of the 7th month following year-end.
• 12th month post fiscal year-end: The Master File (Form F. 2673) is due between the 23rd and 27th calendar days of the 12th month following year-end.

Tested party selection rules

• Default principle: The local entity must serve as the tested party for comparability analysis.
• Foreign tested party exception: The non-resident entity may be selected as the tested party only if its functions, assets, and risks are less complex, and the selected methodology is resale price, cost plus, or transactional net margin method (TNMM). Furthermore, the underlying transaction must fall into one of four listed categories:
  • Intra-group services received by the local entity (excluding financial transactions under Art. 19).
  • Transactions with foreign related trade intermediaries.
  • Goods imports representing less than 2% of total operating costs in the fiscal period.
  • Goods exports representing less than 2% of total sales in the fiscal period.
• Concurrent eligibility requirements: Testing the foreign entity requires reliable, audited accounting data, fewer required comparability adjustments, and no exploitation of unique or valuable intangibles by the foreign party.

Prohibition of downward adjustments

• Taxpayers are generally prohibited from making self-initiated downward transfer pricing adjustments on their tax returns. This means they cannot reduce taxable income or increase tax-deductible expenses through such adjustments.
• An exception applies where the adjustment results from a Mutual Agreement Procedure (MAP) formally agreed under an applicable Double Taxation Convention.

Low value-added services safe harbour

• Arm’s length margin standard: Intra-group support services deemed “low value-added” (auxiliary functions that do not form part of core activities, require no unique/valuable intangibles, and involve minimal risk) are deemed compliant without a formal comparability study if the profit markup on total operating costs and expenses is:
  • At least 5% when the service provider is a local entity.
  • At most 5% when the service provider is a foreign related party.
• Cumulative eligibility conditions:
  • Volume cap: Total received low value-added services must not exceed 10% of local operating expenses (or provided services must not exceed 10% of local operating income).
  • No operating losses: The local tested entity must not report operating losses in the current fiscal period.No Business Restructuring: The local tested entity must not be undergoing a business restructuring process.