Argentina’s Agency for Collection and Customs Control (ARCA) published General Resolution 5798. This publication substantially updates the transfer pricing and international operations regimes, amending RG 4717 and 5010. The regulation redefines the billing and operations thresholds that determine information obligations, aligning with the new economic context and the provisions of Decree 767/2025.
What are the changes regarding transfer pricing?
The main impact is observed in the significant increase of the minimum amounts to be covered by the General Regime and the Simplified Regime. For example, the total income threshold for the General Regime goes from ARS 30 million to ARS 1,500 million (USD 1.03 million), and the Simplified Regime limit rises to ARS 3,000 million (USD 1.98 million).
Likewise, operations with related parties or non-cooperative jurisdictions are updated to ARS 150 million in total (€103,350.30) or ARS 15 million per individual operation.
Regarding the Master File, the regulation introduces a key improvement for multinational groups. This means that when there are no changes with respect to the last report submitted, the submission of a ratification note in the form of an affidavit will be enabled, avoiding the complete re-upload of the documentation. This option is channeled through the new Form F. 2673 and seeks to significantly reduce the recurring administrative burden.
Modifications in transfer pricing
Additionally, relevant procedural adjustments are incorporated, such as the requirement for digital signatures from the taxpayer, the certifying professional, and the professional council in the Transfer Pricing Study and Form F. 4501 in Argentina. The operation of “no movement” submissions is also simplified, exempting taxpayers who have reported two consecutive periods under that condition from the F. 2668 affidavit, until the situation changes.
Conclusions
The provisions enter into force upon their publication in the Official Gazette (December 12, 2025) and are applicable to fiscal years closed as of October 31, 2025. Altogether, RG 5798 marks a relevant change in compliance management in Argentina, with an approach more aligned with international standards and a concrete reduction of formal burdens for economic groups with cross-border operations.
Auxadi can help you in your international expansion into Latin America, thanks to its transfer pricing services through TPS by Auxadi. Do not hesitate to contact us.
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Author:
Julieta Eidelstein
Tax Supervisor – AR
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