The Argentine tax administration has recently introduced significant changes to the transfer pricing and international transactions regime through General Resolution 5798/2025, published by the Customs Collection and Control Agency (ARCA). This regulation updates and adjusts key provisions contained in General Resolution 4.717 and General Resolution 5.010, which regulate documentation, information, and compliance requirements for transactions with related parties abroad and transactions with low- or no-tax jurisdictions.
The regulatory update is part of a regional and international context of greater demands for fiscal transparency, in line with OECD standards and the recommendations of the BEPS project, particularly with regard to transfer pricing documentation and the analysis of cross-border transactions.
General scope of General Resolution 5798/2025
RG 5798/2025 does not create a new regime, but rather introduces technical and quantitative adjustments to the current rules, with the aim of adapting them to the current economic reality and improving the efficiency of tax control. In general terms, the resolution:
- Updates economic thresholds that determine the obligation to submit transfer pricing documentation and information.
- Specifies the conditions under which the submission of the Master File is required.
- Introduces changes to the forms and submission procedures, reinforcing the use of electronic means and the standardization of the information reported.
- Defines the time frame for application, establishing its validity for certain future tax periods.
These changes directly impact taxpayers who carry out international transactions, especially those who are part of multinational groups.
Update of thresholds and their practical impact
One of the most relevant aspects of RG 5798/2025 is the update of the minimum amounts that determine the obligation to comply with the information and documentation regimes provided for in Argentine transfer pricing regulations.
The resolution increases the values that, until now, had fallen behind inflation and the nominal growth of international transactions. This adjustment has a double effect:
- On the one hand, it excludes from the regime certain taxpayers whose transactions, although they exceeded the historical thresholds, do not reach the new updated values.
- On the other hand, it keeps economic groups with significant cross-border transactions under enhanced scrutiny, focusing control on those cases of greater fiscal materiality.
From a technical perspective, this change does not imply a relaxation of the regime, but rather a better targeting of fiscal risk, consistent with international tax administration practices.
Master File: clarifications on its enforceability
RG 5798/2025 introduces adjustments in relation to the obligation to file the Master File, a document that is part of the three-level transfer pricing documentation scheme (Local File, Master File, and CbC Report).
In particular, the regulation redefines the circumstances in which entities resident in Argentina that are members of multinational groups must file this report, considering variables such as:
- The level of consolidated income of the multinational group.
- The magnitude of international transactions with related parties.
- The status of controlling entity, sub-controlling entity, or local entity that is part of the group.
These clarifications seek to avoid ambiguous interpretations and standardize compliance, aligning the scope of the Master File with the criteria used by other jurisdictions that apply OECD standards.
Changes in forms and filing procedures
Another central focus of the resolution is the modification of formal compliance instruments, including the forms used to report transfer pricing and international transaction information, such as Form F.2673 and others.
RG 5798/2025 reinforces the mandatory nature of:
- Exclusively electronic filings through the systems enabled by ARCA.
- Use of standardized formats, which facilitate the cross-checking of information and risk analysis by the tax administration.
- Greater accuracy in the information reported, especially with regard to related parties, valuation methods, and economic results.
From a professional practice perspective, these changes require greater coordination between the tax, accounting, and financial areas of taxpayers, as well as adequate traceability of the information reported.
Validity and periods covered
The regulation establishes that the amendments introduced are applicable for tax periods ending on or after a specific date in 2025, which means that many companies will have to consider these changes in the planning and fulfillment of their future obligations, even if the corresponding documentation is prepared and submitted in subsequent years.
This aspect is particularly relevant, as the preparation of transfer pricing studies and information reports requires advance planning, both in terms of information gathering and technical analysis.
Technical considerations and compliance risks
From a transfer pricing perspective, RG 5798/2025 reinforces a clear message: the Argentine tax administration continues to deepen an information-based control approach, with an emphasis on consistency between reported results, submitted documentation, and the economic reality of intragroup transactions.
In this context, the main risks for taxpayers include:
- Incomplete or inconsistent filings with the functional and economic reality of the group.
- Misalignment between the Local Report and the Master Report.
- Use of valuation methodologies that are not technically supported.
- Formal errors in the filing of forms and deadlines.
Recommendations from a professional perspective
Given this regulatory scenario, it is advisable for companies with international operations to:
- Review in a timely manner whether the new thresholds change their status as reporting entities.
- Assess the impact of the regulation on their current transfer pricing policies.
- Ensure documentary consistency between the different levels of information required.
- Strengthen their internal data collection and validation processes.
From a technical perspective, these types of regulatory updates should be analyzed not only from a formal compliance standpoint, but also from a comprehensive tax risk management perspective, considering their impact on documentation, the consistency of the information reported, and the taxpayer’s position in the event of any audit proceedings.
Properly manage the impact of this regulatory update
General Resolution 5798/2025 represents a significant update to the Argentine transfer pricing and international transactions regime. While it does not modify the structural principles of the system, it introduces adjustments that directly impact the scope, form, and timing of compliance, especially for multinational groups with significant cross-border operations.
In a context of increasing tax scrutiny and strengthening control mechanisms, it is essential that companies promptly assess the impact of these changes on their documentation obligations, transfer pricing policies, and internal reporting processes. Correct technical interpretation and consistent implementation not only enable compliance with current regulations but also reduce contingencies and strengthen tax defense before the tax authority.
Having the support of a company specializing in transfer pricing allows these updates to be addressed from a preventive and strategic approach, ensuring alignment with applicable technical standards and the economic reality of intra-group operations.
Source: Argentina.gob.ar