The decree updates and clarifies rules for importers and exporters, particularly regarding transfer pricing and reporting for quoted goods.

RF Report

Argentina published Decree 767/2025 in the Official Gazette on 28 October 2025, introducing significant updates to its cross-border transaction reporting rules, effective for fiscal years ending on or after 29 October 2025.

The decree focuses primarily on updating and clarifying regulations regarding international operations for both importers and exporters, particularly concerning transfer pricing and the reporting of transactions involving “goods with quotation.

Key changes include adjusting the monetary thresholds above which taxpayers must supply information to Argentina’s customs and tax authority (ARCA), modifying the criteria for determining if prices are between independent parties, and establishing detailed reporting requirements for the sale of quoted goods.

Additionally, the decree expands the scope of an optional, simplified Income Tax declaration modality to potentially include foreign-source income as determined by the Agency, aligning with the government’s goal of tax simplification.

The key updates are:

Higher exemption threshold for trade reporting: Entities engaged in import/export of goods with independent third parties are now exempt from providing information to the ARCA if their annual trade volume is below USD 500 million.

Transfer pricing and master file exemptions: Companies are no longer required to submit a transfer pricing study or Master file if their transactions with related parties abroad, or with entities in low or no-tax or non-cooperative jurisdictions, remain under USD 150 million annually or USD 15 million per transaction.

Mandatory electronic registration for export contracts: Export contracts for goods with quotations must be registered electronically within 60 days of shipment, in accordance with ARCA’s guidelines. The taxpayer must maintain the corresponding supporting documentation.

Specific regulations for export of quoted goods: The scope of “quoted goods” now includes those involving specialised public entities. Previously, “Quoted goods” were defined as physical products that possess or adopt prices of public and notorious knowledge negotiated in transparent markets, commodity exchanges, or similar venues, nationally or internationally.

Clarification of market parameters: The decree provides more explicit rules for transactions conducted in transparent markets.