On September 30, 2026, the Customs Collection and Control Agency (ARCA) published the General Resolution 5903/2026 in the Official Gazette, which establishes the new Transfer Pricing regime in Argentina. The regulation repeals General Resolutions 4717, 4733, 4759, 5010, and 5798, as well as consolidates the general and simplified regimes for international transactions into a single text.
The change is not merely formal. The resolution raises the filing thresholds, adjusts the deadlines, and adds new technical rules for low-value services, international intermediaries, and Transfer Pricing adjustments.
When does it take effect?
The resolution took effect on the date of its publication and applies to fiscal years beginning on or after the first day of the following month—that is, October 1, 2026. For a company with a fiscal year-end on December 31, the first fiscal year covered by the new regime begins on January 1, 2027.
This is a significant difference from the draft submitted for public comment, which proposed applying the new rules to fiscal years ending on or after December 31, 2025.
Who is required to submit?
The resolution establishes new thresholds (in Argentine pesos):
| Obligation | When does it apply? |
| Local File | Transactions with related parties totaling more than USD 3 billion or USD 600 million per transaction. |
| Reporting System F.2668 | Imports or exports with unrelated parties totaling more than USD 7.5 billion, or transactions with related parties totaling more than USD 1.5 billion collectively or USD 300 million per transaction. |
| Master File | Groups with consolidated annual revenues exceeding USD 500 billion, among other requirements. |
Members of multinational groups required to file the Country by Country Report are subject to special rules: they must file a Local File when their transactions with related parties exceed the thresholds set forth in Form F.2668, and they may not opt for the simplified regime.
The amounts will be updated annually based on the change in the Consumer Price Index (CPI) from October to October. The first update will apply to fiscal years beginning on or after January 1, 2028.
What has changed in technical analysis?
- Low-value-added services: The regulation allows for the payment of these services without a full comparability analysis. If the service provider is the local entity, the markup on costs must be at least 5%; if the service provider is the related party abroad, it may be up to 5%. To use this option, the low-value services received cannot exceed 10% of operating expenses or revenue, and the company must not have operating losses or be undergoing restructuring.
- Analyzed foreign party: It is permissible to select the foreign party as the analyzed party in certain cases of minor significance, for example, exports of goods accounting for less than 2% of total sales for the period.
- Adjustments in favor of the taxpayer: Downward Transfer Pricing adjustments may only be reflected on the affidavit if they result from a mutual agreement procedure under a double taxation treaty.
- International intermediaries: In foreign trade transactions involving foreign intermediaries, the regulation requires proving their substance, documenting their functional analysis, and demonstrating that their compensation is consistent with the functions they perform.
What happens to those who do not meet the thresholds?
Failure to submit the study does not exempt a taxpayer from agreeing to arm’s-length values. Those who fall below the thresholds must comply with the other obligations of the regime that apply to them.
In addition, ARCA may require certain taxpayers to submit a Local File when market conditions or the level of risk warrant it. In that case, the taxpayer has 45 days from the date of notification to submit the Local File and its working papers.
What are the new deadlines?
The Local File (along with Form F.2668 or Form F.2672) must be filed in the seventh month following the end of the fiscal year, and the Master File must be filed in the twelfth month, depending on the last digit of the CUIT (Argentine Tax Identification Number):
| CUIT last digit | Local File | Master File |
| 0 or 1 | Until the 2nd | Until the 23rd |
| 2 or 3 | Until the 3rd | Until the 24th |
| 4 or 5 | Until the 4th | Until the 25th |
| 6 or 7 | Until the 5th | Until the 26th |
| 8 or 9 | Until the 6th | Until the 27th |
If the due date falls on a non-business day, it is extended to the next business day. Any entity that reports two consecutive “inactive” periods is exempt from the reporting requirements until it exceeds the thresholds again.
At TPC Group, in every Transfer Pricing analysis in Argentina, we determine which obligations under RG 5903/2026 apply based on each company’s profile and transactions. Our objective is to ensure that the documentation for the first fiscal years is aligned with the new rules from the outset.
Sources
- Official Gazette of the Republic of Argentina
- Microjuris