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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

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.

  • Transactions with related parties/non-cooperating countries and/or low- or no-tax jurisdictions (for tax return forms 2668 and 4501) (Art. 44, GR 4717) increase 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) increases to $100,000,000,000.
  • Regarding the Master File requirements (Art. 45, GR 4717), both of the following conditions must be met for the obligation to apply:
    • Consolidated annual group income exceeds the updated amount of USD 100,000,000,000 in the prior fiscal year; and
    • Related party transactions exceed 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) change 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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