Transfer Pricing and International Transactions – Barreiro

Analysis of ARCA General Resolution 5798/2025

Transfer Pricing and International Transactions. Increase in the thresholds for information reporting

(Amendments to General Resolutions 4717 and 5010)

Key changes introduced by General Resolution 4717 (general regime)

1.1. Increase in thresholds that trigger reporting obligations

General Resolution 5798/2025 introduces amendments to the transfer pricing and international transactions regime. In this regard, the resolution increases the thresholds from which taxpayers are required to submit information. The changes can be summarized as follows:

a) Transactions with international intermediaries – Article 41
Before: ARS 30 million
Now: ARS 1.5 billion

This means that it is no longer necessary to retain:
a) the intermediary’s audited financial statements, nor
b) the certification issued by an independent professional qualified in the relevant jurisdiction regarding the remuneration of the international intermediary related to its participation in the transactions, nor the details of purchase and sale prices and transaction-related expenses, when the party is related.

b) Thresholds for transactions with related parties requiring the submission of a Transfer Pricing Study – Article 44

Total annual amount:
Before: ARS 3 million
Now: ARS 150 million

Individual amount per transaction:
Before: ARS 300,000
Now: ARS 15 million

1.2. New framework for the “Master File” (Article 45)

Article 45 is fully replaced and redefines when there is an obligation to file a Master File.

Cumulative requirements (both must be met):

Consolidated annual revenues of the multinational group:
More than ARS 100 billion in the prior fiscal year.
Transactions with foreign related parties:
More than ARS 150 million in total, or
More than ARS 15 million per individual transaction.

This limits the obligation exclusively to large-scale multinational groups, in line with the BEPS approach.

Important new feature: Confirmation note

If there were no changes compared to the last Master File:

A confirmation note, filed as a sworn statement, may be submitted in lieu of the full report.
Submission of the Master File in the immediately preceding period is mandatory.

This introduces a concrete reduction in administrative burden for stable groups.

Filing and formal requirements

Form F. 2673 is formally introduced as the specific form.
The designation of a single reporting entity in Argentina is allowed when there are multiple local entities within the same group.
Official translation requirements are reinforced for documentation in foreign languages.

1.3. Changes to the Transfer Pricing Study – Form F. 4501 (Article 46)

The regulation:

Unifies the submission of the Transfer Pricing Study, professional certification, and digital signatures within Form F. 4501.
Strengthens the requirement for digital signatures from:
- the taxpayer,
- the certifying professional, and
- the Professional Council.

A fully digital framework is consolidated, with greater traceability and professional accountability.

1.4. “No transactions” regime – Form F. 2668 (Article 47)

This change is particularly relevant in practice:

If a taxpayer has no transactions or does not exceed the thresholds, but filed “with transactions” in any of the last two fiscal years, they must continue filing Form F. 2668 (“no transactions”).
After two consecutive periods with no transactions, the taxpayer is exempt from further filings until their situation changes.

Changes introduced to General Resolution 5010 (simplified regime)

General Resolution 5798 also significantly expands the scope of the Simplified Regime for International Transactions.

New economic thresholds

Before: between ARS 10 million and ARS 60 million
Now: between ARS 500 million and ARS 3 billion

This allows the simplified regime to be used by medium-sized companies with moderate international transactions.

Adjustment of information thresholds

The amounts are aligned with the new thresholds of the general regime (ARS 150 million / ARS 15 million).

Effective date and temporal application

Effective date: as from publication in the Official Gazette.
Application: fiscal years ending as of October 31, 2025.
Form F. 2673 must be used for all filings (including amended filings) made from the effective date onward, regardless of the fiscal period reported.

Conclusion

ARCA General Resolution 5798/2025:

Updates thresholds that had become outdated.
Reduces obligations for lower tax-risk taxpayers.
Focuses controls on multinational groups and material transactions.
Introduces concrete operational simplifications (confirmation notes, an end to indefinite “no transactions” filings).

From a practical perspective, the regulation eases the compliance burden, but requires greater technical rigor from taxpayers who remain subject to the regime.