Argentina: Key Transfer Pricing Due Dates in 2025

Imminent Deadlines for Transfer Pricing Filings

The parties required to file Transfer Pricing returns are those local entities carrying out related-party transactions with foreign entities, Low or No Tax Jurisdictions (LNTJs), or Non-Cooperating Jurisdictions (NCJs). The following addresses the principal Transfer Pricing obligations to be filed before the ARCA (Agencia de Recaudación y Control Aduanero – Customs Collection and Control Agency): 

• Form 2668: The scope is for those local subjects performing transactions with foreign related parties or those based in JBNT or JNC (tax havens) subject to the Transfer Pricing regime jointly in the annual period exceeding $ 3,000,000 or individually $300,000. It should be noted that it is possible to file the form “without movement.” 
• Form 4501: It is filed along with Form 2668. It is the form through which the Transfer Pricing Study is filed, along with the independent public accountant’s certification. The above form must have the “digital signature” of the taxpayer and/or party in charge, the public accountant involved, and the representative of the Professional Council, college, or entity in which such professional is registered. 
• Form 2672: Those obliged to file the Transfer Pricing study or the affidavit of international operations (F.2668) may replace compliance with both obligations, as applicable, through the Simplified International Operations Regime. As long as they do not import and export through international intermediaries, nor file a Master File, or the Group is subject to filing the Country-by-Country report. 
• Master File: It must be filed by local members of MNE Groups with consolidated revenues exceeding $ 4,000 million, reporting the structure, functions, policies, assets, and risks of the MNE Group. 

What Are the Due Dates for Such Obligations?

• Forms 2668/4501 and 2672 are filed within the sixth month after the end of the fiscal year. For example, if the taxpayer has closed its fiscal year on December 31, they must file such obligations until June 30, 2025. 
• Regarding the Master File, the due date is within the twelfth month after the annual fiscal year-end. Considering the above example, the due date of the Report would be 12/30/2025. 

Established Due Dates on December 31, 2024, as the Fiscal Year-End

It should be noted that the exact due date is established according to the fiscal year-end of each taxpayer and the last CUIT (Clave Única de Identificación Tributaria – Single Tax Identification Key/TIN) digit. The following is the schedule of due dates published by the ARCA for those taxpayers that had a fiscal year-end as of December 31, 2024: 

Timely Compliance Importance

Complying with these obligations within the deadline is essential to avoid penalties, audits, or tax adjustments. In addition, it allows for demonstrating transparency in international transactions. Companies must ensure well-founded reports and correct supporting documentation. 

Conclusion and Recommendations

Companies must urgently review their situation and work on preparing their reports. Acting in advance is key to avoiding risks. Specialized advice can ensure regulatory compliance and tax peace of mind. 

Is Your Company Prepared for These Obligations?

At TPC Group, we provide the technical and legal support you need to prepare and file your Transfer Pricing documentation with the ARCA. Contact us and ensure smooth compliance! 

Source: CPCE