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 a mandatory electronic registry for certain listed goods, and redefines reporting obligations to the tax authority.
These adjustments seek to balance the administrative burden on companies with more effective control over high-value transactions.
Main changes introduced by Decree 767/2025
The decree updates several articles of the Income Tax regulations, with a clear focus on foreign trade transactions.
Among the main changes are:
- The 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 submitting information to the tax authority.
These changes respond to a demand from the export sector, which had been calling 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, with regard to the Information Regime for import and export transactions of tangible goods with independent companies based in cooperating countries, the threshold for filing has been 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 the obligation to submit the Local Report documentation 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: it seeks to ensure that transactions are correctly valued from the outset. Therefore, companies must keep sufficient evidence to demonstrate compliance with the arm’s length principle.
The register of export contracts 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 implies the need to review internal transfer pricing policies and adjust documentation models. The standard adopts the interquartile range as a valid reference for evaluating margins and prices, aligning with 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 contemporary documentation, becomes an essential practice for mitigating risks.
Strategic implications for Argentine foreign trade
In a context of high economic volatility, raising thresholds could boost the competitiveness of medium-sized exporters. However, it also represents a greater challenge for large companies, which will have to justify the reasonableness of 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 the way Argentina supervises international operations. By raising thresholds and strengthening the traceability of export contracts, the country seeks a balance between simplification and control.
Companies will need to take a proactive stance, reviewing their pricing methodologies, adjusting their documentation, and ensuring consistency with international criteria.
Specialized transfer pricing advice
At TPC Group, we advise multinational groups and local companies on the correct application of transfer pricing rules, helping them to comply with AFIP and OECD requirements, mitigate risks, and optimize their tax position.
Contact us today for a personalized review of your transfer pricing policy and compliance strategy.
Source:
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https://www.primeraedicion.com.ar/nota/101053920/actualizan-reglas-precios-transferencia-exportadores-2025/
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Decree 767/2025 - Modification of the Transfer Pricing Regime.