The draft legislation details rules, methodologies (such as the use of median and interquartile range), and documentation requirements for justifying prices in transactions involving both affiliated and independent foreign entities, as well as those in non-cooperative or low-tax jurisdictions.
Argentina’s tax and customs agency (ARCA) has initiated a public consultation on a draft regulation to replace General Resolution No. 4717/2020 on transfer pricing and international transactions on 9 December 2025.
This resolution, which addresses Income Tax and international operations, is intended to replace prior regulations governing the transfer pricing regime. The draft legislation details rules, methodologies (such as the use of median and interquartile range), and documentation requirements for justifying prices in transactions involving both affiliated and independent foreign entities, as well as those in non-cooperative or low-tax jurisdictions.
Furthermore, it mandates the presentation of a transfer pricing study and, for certain multinational groups, a Master File. It includes details on the subjects obligated to comply, the types of operations covered, and the associated filing deadlines.
The public consultation process allows stakeholders to review and provide feedback on draft regulations prepared by the tax agency. The deadline for submitting comments is 12 December 2025, and comments should be sent through the “Participatory Rulemaking” service using the Tax ID.
