Transfer pricing
Last verified: 24 Oct 2026 · Status: Changing
Transactions with foreign related parties and with entities in non cooperating or low tax jurisdictions must follow the arm's length principle (articles 17 to 20 of the Income Tax Law and Decree 862/2019). ARCA General Resolution 5903/2026, published 30 Sep 2026, replaced RG 4717/2020 and RG 5010 for fiscal years starting from 1 Oct 2026, keeping the simplified regime for small taxpayers.
Peso amounts are converted at the dólar MEP (bolsa) selling rate of ARS 1,563.90 per US$ on 23 Oct 2026 (source: dolarapi.com, MEP quote). Conversions are indicative and move daily.
Key rules
- Scope. Imports and exports between independent parties above thresholds, transactions with foreign related parties, permanent establishments, and non cooperating or low tax jurisdictions (RG 5903, art. 1 and 2).
- Information return F.2668. Required when independent imports and exports exceed ARS 7,500,000,000 (about US$4,795,703), or transfer pricing transactions exceed ARS 1,500,000,000 (about US$959,141) in total or ARS 300,000,000 (about US$191,828) individually (art. 58).
- Transfer pricing study. Required above ARS 3,000,000,000 (about US$1,918,281) in total or ARS 600,000,000 (about US$383,656) individually, or for groups filing country by country reports. Certified by an independent accountant or economist (art. 60 and 61).
- Master file. Required for multinational groups with consolidated revenue above ARS 500,000,000,000 (about US$319,713,537) that also exceed the study thresholds (art. 63).
- Low value services. Optional safe harbour: a markup of at least 5% when the local entity provides, or at most 5% when a foreign related party provides, if the services stay within 10% of operating costs or income (art. 17).
- Commodity exports. Official FOB values for soy, corn, wheat and sunflower products may be used as minimum values (art. 41). Specific rules for international intermediaries (art. 31 to 33, 55).
- Simplified regime. Small taxpayers meeting the tests in art. 64 file F.2672 instead of the study and F.2668.
- Thresholds indexed. First CPI update applies to fiscal years from 1 Jan 2028 (art. 75).
Costs and timelines
| Filing | Due (RG 5903, art. 70) |
|---|---|
| Study and F.2668, or F.2672 | Seventh month after year end, days 2 to 6 by CUIT ending |
| Master file | Twelfth month after year end, days 23 to 27 by CUIT ending |
International comparison
No comparison figures for this topic have been verified from an official source yet, so the cells are left blank on purpose. We only fill a cell from an official registry, statute or the OECD and World Bank datasets.
| Jurisdiction | Comparable rule |
|---|---|
| Argentina | Not yet sourced |
| US (Delaware) | Not yet sourced |
| UK | Not yet sourced |
| Canada | Not yet sourced |
| Chile | Not yet sourced |
| Uruguay | Not yet sourced |
| Brazil | Not yet sourced |
| Singapore | Not yet sourced |
| Estonia | Not yet sourced |
Practical traps
- Downward adjustments cannot be taken in the return unless they come from a treaty mutual agreement procedure (art. 48).
- Loss making comparables are excluded unless justified (art. 8).
- Foreign language documents may need a sworn translation on request.
Recent changes
- 30 Sep 2026. RG 5903/2026 published. Applies to fiscal years starting from 1 Oct 2026. RG 4717 still governs earlier years.