On December 16, 2025, the Customs and Revenue Agency (ARCA) published General Resolution 5798/2025 in the Official Gazette of the Argentine Republic, introducing significant changes to the transfer pricing and international transactions regime. This regulatory update, which amends General Resolutions Nos. 4,717 and 5,010, has an impact on the reporting requirements and obligations of companies operating internationally and within Argentine territory.
Context and scope of General Resolution 5798/2025
RG 5798/2025 arises within the framework of the update of regulatory thresholds defined by Decree No. 767/2025, which empowered ARCA to adjust the amounts above which taxpayers must comply with reporting obligations relating to international transactions and transfer pricing. These types of updates are crucial to keeping regulations aligned with the economic context and international standards of fiscal transparency.
The changes introduced by the regulation generally apply to tax periods ending on or after October 31, 2025, although some operating procedures are already enforceable as of its publication.
Main changes and new thresholds
1. Raising of reporting thresholds
One of the most significant changes in the Resolution is the substantial increase in the turnover and transaction thresholds that determine reporting obligations under the transfer pricing and international transactions regime. These updates seek to reflect current economic dynamics and prevent formal obligations from falling on companies with lower levels of activity.
Among the most important adjustments:
- General control threshold: raised from $30,000,000 to $1,500,000,000, marking the minimum income that requires compliance with reporting requirements.
- Individual minimum for related-party transactions: increased from $300,000 to $15,000,000 for each related-party transaction.
- Limit for filing the Master Report: increased from $3,000,000 to $150,000,000 in total transactions with related parties.
These adjustments represent a significant increase in reporting thresholds, which may exempt certain companies from more complex reporting obligations if their transactions do not exceed the new amounts established.
2. Changes in reporting obligations
The regulation also redefines how certain reports must be filed, including:
- The filing of the “Master Report,” which is now conditional on two criteria being met jointly:
- a) that the multinational group has consolidated revenues exceeding $100,000,000,000, and
- b) that transactions with related parties exceed $150,000,000 in the fiscal period.
- When there are no changes in the data reported with respect to the previous period, companies may opt for a ratification note in the form of a sworn statement instead of filing a new Master Report.
- The requirements regarding the sworn statement F. 4501 are also updated, which must contain the Transfer Pricing Study, professional certifications, and digital signatures of the taxpayer and the professionals involved.
3. Adjustments to the simplified regime (RG 5.010)
At the same time, General Resolution 5798/2025 modifies some parameters of the Simplified Regime for International Transactions, raising the ranges in which companies can opt for this reporting scheme.
The update of these parameters seeks to balance formal obligations with the operational reality of companies that, although they carry out international operations, do not reach certain levels of turnover or transaction volume.
Key implications for companies
Tax compliance and international tax planning
The update of thresholds and requirements forces companies to review their internal tax compliance policies and evaluate their transfer pricing structures. This is especially relevant for multinational groups operating in Argentina that may see changes in the treatment of their reporting obligations or documentation procedures.
Impact on medium and large companies
Companies with revenues below the new thresholds may see their formal compliance burden reduced, while those exceeding the updated limits will need to anticipate the preparation of more robust technical documentation. This may involve:
- Reviewing and updating transfer pricing studies,
- Coordinating with internal audit teams, and
- Providing a higher level of documentary evidence to justify profit allocation policies and intercompany transactions.
Relevance for corporate management
From the perspective of senior management and finance departments, the regulatory change reinforces the need to have information and control processes aligned with international standards, including the adoption of best practices in documentation and functional analysis to support transfer pricing decisions before tax authorities.
Conclusion: adaptation and anticipation as a competitive advantage
General Resolution 5798/2025 marks a stage of regulatory adaptation in Argentina which, by updating thresholds and formal obligations, seeks to balance the compliance burden with current economic realities and the principles of fiscal transparency. For companies subject to the transfer pricing regime, this change is an opportunity to:
- Optimize their tax documentation processes,
- Strengthen their internal tax compliance policies, and
- Prepare for possible reviews by ARCA and other competent authorities.
Proper interpretation and application of these regulations not only fulfills a legal obligation, but also strengthens tax risk management and consolidates the confidence of investors and key stakeholders in an increasingly demanding environment in terms of transparency and corporate governance.
Anticipate risks and strengthen your transfer pricing compliance
The changes introduced by RG 5798/2025 require a timely review of transfer pricing policies, applicable thresholds, and reporting obligations in Argentina. A preventive assessment allows you to reduce tax contingencies, optimize compliance processes, and ensure that intra-group transactions are aligned with the arm’s length principle and current regulatory standards.
At TPC Group, as a company specializing in transfer pricing, we assist multinational groups in the technical analysis, documentation, and risk management associated with transfer pricing and international taxation, providing a business-oriented strategic vision.
Source: Boletín Oficial