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Argentina: Changes to transfer pricing regimes; amendments to system for issuing receipts using “fiscal controllers”

Changes to transfer pricing regimes applicable for fiscal periods ending on or after October 31, 2025

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December 19, 2025

General Resolution 5798/2025 (published in the official gazette on December 16, 2025) makes various changes to the transfer pricing regimes established in General Resolutions 4717 and 5010, applicable for fiscal periods ending on or after October 31, 2025.

  • Total income for general regime (Art. 41, GR 4717) increases from $30,000,000* to $1,500,000,000.
  • Transactions with related parties/non-cooperating countries (for tax return form 2668) (Art. 44, GR 4717) increases from a total of $3,000,000 or an individual amount of $300,000 to a total of $150,000,000 or an individual amount of $15,000,000.
  • Consolidated annual group income (for Master file) (Art. 45, GR 4717) remains unchanged but the transaction threshold is updated to $100,000,000,000.
  • Related party transactions for the Master file Report (Art. 45, RG 4717) is set at a total of $150,000,000 or an individual amount of $15,000,000.
  • The maximum limit for the simplified regime (RG 5010) (Art. 1, RG 5010) changes from less than $60,000,000 to less than $3,000,000,000.
  • Related party transactions for the simplified regime (Art. 7, RG 5010) changes from a total of $3,000,000 or an individual amount of $300,000 to a total of $150,000,000 or an individual amount of $15,000,000.
  • The procedure for filing tax return form 2668 (no transactions) (Art. 47, RG 4717) is modified.

In addition, General Resolution 5801/2025 (published in the official gazette on December 16, 2025) amends General Resolution No. 3561, which established a system for issuing receipts using electronic equipment called “fiscal controllers.” Specifically, starting with the reports corresponding to the month of January 2026, registered taxpayers and exempt entities must submit the digital audit trail report (CTD) (F. 8010) and the summary of totals report (F. 8011) on a monthly basis. The deadline for submission will be the 5th day of the month following the reporting period.

Read a December 2025 report (Spanish) prepared by the KPMG member firm in Argentina

*$=Argentine peso

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