The recent amendment to the Transfer Pricing regime in Argentina, established by Decree 767/2025, marks a significant change for exporters and importers. The main objective is to modernize controls on international transactions and align valuation criteria with global tax transparency standards.
The new scheme raises reporting thresholds, incorporates mandatory e-registration for certain listed goods, and redefines reporting obligations to the tax authority.
These adjustments aim to balance the administrative burden on companies with more effective control over high-value transactions.
Main Amendments Introduced by Decree 767/2025
The decree updates several articles of the Income Tax Regulations, focused on foreign trade transactions.
The main amendments include:
- An increase in the minimum threshold above which international transactions must be reported.
- The creation of a specific registry for exports of publicly traded goods.
- The definition of specific deadlines for reporting to the tax authority.
These amendments respond to a demand from the export sector, which had been claiming for more predictable rules adapted to the current economic context.
New Thresholds: Relief for Some, Greater Demands for Others
The thresholds applicable to certain Transfer Pricing information and documentation regimes are updated. First, regarding the Reporting Regime for import and export transactions of tangible goods with independent companies based in cooperating countries, the filing threshold is increased from AR$10,000,000 to AR$500,000,000 per fiscal year.
Likewise, within the framework of the Transfer Pricing regime, the fourth paragraph of Article 55 of the Regulatory Decree of the Income Tax Law is replaced, raising the threshold for filing the Local Report and the F.2668 affidavit from AR$3,000,000 to AR$150,000,000 per fiscal year.
Operational Requirements and Documentation
The new regime introduces a preventive approach: Ensuring that transactions are correctly valued from the outset. Therefore, companies must keep sufficient evidence to demonstrate compliance with the Arm’s Length Principle.
The export contract register must include:
- Identification of the buyer or recipient abroad.
- Details of agreed prices and commercial conditions.
- Specifications of the exported goods or services.
Failure to meet the deadline or lack of documentation could result in significant tax adjustments or questions from the authorities.
Risks and Best Practices for Multinational Companies
For groups with international operations, this update requires them to review their internal Transfer Pricing policies and adjust their documentation models. The standard adopts the interquartile range as a valid reference for evaluating margins and prices, aligning with the OECD standards.
Likewise, companies must be prepared for cross-audits and consistency checks between customs and tax declarations. The implementation of robust internal controls, supported by comparable analysis and up-to-date documentation, is crucial to reducing risks.
Strategic Implications for Argentine Foreign Trade
In a context of high economic volatility, raising thresholds could boost the competitiveness of medium-sized exporters. Conversely, it also represents a greater challenge for large companies that must support their prices under a more rigorous control scheme.
The new system reinforces international fiscal transparency, but requires more sophisticated technical management of information. Planning and timely compliance will be key to avoiding penalties and maintaining operational efficiency.
Conclusion
Decree 767/2025 redefines how Argentina supervises international transactions. When the country raises its thresholds and strengthens the traceability of export contracts, it strikes a balance between simplification and control.
Companies must take a proactive stance by reviewing their pricing methodologies, adjusting their documentation, and ensuring consistency with international criteria.
Specialized Transfer Pricing Advice
TPC Group advises multinational groups and local companies on the correct application of Transfer Pricing rules, enabling them to comply with AFIP (Administración Federal de Ingresos Públicos – Federal Administration of Public Income) and the OECD requirements, mitigate risks, and optimize their tax position.
Contact us today for a customized review of your Transfer Pricing policy and compliance strategy.
Source:
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Primera Edición
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Decree 767/2025 - Modification of the Transfer Pricing Regime.