Argentina - Revises Transfer Pricing Rules for International Transactions

Summary

On September 28, 2026, Argentina’s tax authority (ARCA) issued General Resolution 5903/2026, substantially revising the country’s transfer pricing rules and related compliance requirements. The resolution was published on September 30, 2026, and applies to fiscal years beginning on or after October 1, 2026.

Key Points

1. Revised Transfer Pricing Framework

The resolution updates the rules governing transfer pricing analyses, including tested-party selection, transaction segmentation, comparable selection, comparability adjustments, and the application of the interquartile range and median.

2. Reporting and Documentation Thresholds

Key thresholds include:

• Form F.2668: Covered related-party transactions exceeding ARS 1.5 billion in aggregate or ARS 300 million individually.

• Transfer pricing study: Covered transactions exceeding ARS 3 billion in aggregate or ARS 600 million individually, subject to the applicable requirements.

• Master File: Generally, consolidated group revenue exceeding ARS 500 billion, together with specified thresholds for cross-border related-party transactions.

Separate thresholds and conditions apply to certain transactions with independent parties and other reporting obligations.

3. Comparable Companies and Financial Analysis

The rules address the selection and rejection of comparables, loss-making comparable companies, financial adjustments, and the reconciliation of segmented financial information. Taxpayers must analyze all transactions within scope; random or algorithmic sampling is not permitted.

4. Specific Transaction Categories

The resolution provides detailed rules for services, low-value-adding services, financial transactions, intangible property, commodities and hydrocarbons, international intermediaries, and business restructurings. These rules address matters such as service markups, implicit group support, intangible-related functions, and commodity pricing.

5. Simplified Compliance Regime

Eligible taxpayers may use a simplified international transactions regime under specified conditions. Eligibility restrictions apply, and ARCA may request additional transfer pricing documentation in certain circumstances.

6. Downward Adjustments

Downward transfer pricing adjustments are generally prohibited, except in cases involving mutual agreement procedures under an applicable tax treaty.

7. Filing Deadlines

Transfer pricing studies and the applicable transaction information forms are generally due in the seventh month after the fiscal year-end. Master File filings and related confirmations are generally due in the twelfth month. The specific due date depends on the taxpayer’s identification number and the applicable filing rules.

8. Inflation Adjustments and Transitional Rules

Certain monetary thresholds are subject to annual inflation adjustments. The first adjustment applies to fiscal years beginning on or after January 1, 2028. Previous rules continue to apply to fiscal years beginning before October 1, 2026.

Practical Considerations

Multinational groups operating in Argentina should review whether the revised thresholds affect their filing obligations and reassess their transfer pricing documentation processes before the new rules apply. Particular attention should be given to transaction segmentation, comparable selection, financial reconciliations, and the specific requirements for financial transactions, services, and commodity transactions.

Source

ARCA General Resolution 5903/2026  

https://www.argentina.gob.ar/normativa/nacional/norma-430681/texto

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Disclaimer

This content is for general informational purposes only and does not constitute professional advice.

Information provided herein is based on publicly available sources as of the publication date and may be subject to change.

Armize consulting | Transfer Pricing