Executive summary

On 16 December 2025, General Resolution (ARCA) 5798/2025 (the Resolution) amending General Resolutions (AFIP) 4717, 5010 and 5048 and their amendments, was published in the Official Gazette of the Argentine Republic.

With this Resolution, the Revenue and Customs Control Agency (ARCA) seeks to align the minimum amounts required for compliance with transfer pricing obligations with the provisions of Decree 767 of October 2025. The Resolution also makes adjustments aimed at specifying certain guidelines applicable within the framework of the Transfer Pricing Regime, without prejudice to the comprehensive review process of the Transfer Pricing Regime currently underway. (For background on the Decree 767, see EY Global Tax Alert, Argentina updates income tax regulations affecting transfer pricing compliance obligations, dated 31 October 2025.)

The main amendments that the Resolution incorporates into the Argentine transfer pricing rules are summarized below.

General Regime (GR 4717)

The amount for keeping certain information required by Article 41 of GR 4717 with respect to operations carried out with International Intermediaries is updated, moving from ARS30m to ARS1.5b.

Aligned with the modification to the Regulatory Decree, the minimum amounts for the mandatory annual filings of the Transfer Pricing Study, Master File and Form 2,668 are updated, as follows:

• Transfer pricing study: Applies when the total operations with foreign related entities (according to the extended definition of the regulations) exceeds ARS150m or individual operations that exceed ARS15m
• Master File: Applies to multinational entity (MNE) groups with consolidated annual revenues exceeding ARS100b, and transactions with foreign related entities exceeding ARS150m for groups or ARS15m for individual operations
• Form 2,668: Applies to import and/or export operations of goods with independent parties exceeding ARS500m and/or operations with foreign related parties exceeding ARS150m for groups or ARS 15m for individual operations

Form 2,673 is incorporated for the presentation of the Master File, creating the possibility of filing as a "reporting party" and incorporating other entities of the economic group in the country to this presentation as an "informed party." Informed parties must also submit Form 2,673 providing the data of the reporting party, but do not need to attach the Master File again.

Simplified Regime (GR 5010)

The amounts for the simplified information regime are updated for import and/or export operations of goods with independent parties greater than ARS500m and less than ARS3b. If the total value of transactions with foreign related parties exceeds ARS150m or the individual transactions exceed ARS15m, ARCA may request a Transfer Pricing Report.

The provisions of this resolution will apply for fiscal years ended on or after 31 October 2025, with the exception of the provisions for Form 2,673.

The update regarding Form 2,673 applies immediately for filings made as of the effective date of the rule, regardless of the fiscal period to which it corresponds.

Implications

Affected entities should review their compliance processes in light of these changes regarding transfer pricing documentation, to ensure adherence to the updated regulations.