Argentina: Unified contract registry rules for commodity exports serve as primary transfer pricing control mechanism
The unified rules become effective on August 1, 2026.
The Agency of Collection and Customs Control (ARCA) has published General Resolution 5872/2026, which replaces and unifies the contract registration regime for export operations of goods with market quotations under a single regulatory framework.
The resolution unifies two previously separate regimes—General Resolution 4,653 for agricultural goods and General Resolution 4,837 for other commodities—and serves as the primary transfer pricing control mechanism enabling ARCA to validate agreed export prices when international intermediaries in non-cooperative or low-tax jurisdictions are involved.
The unified rules become effective on August 1, 2026, and require Argentine exporters to register definitive commodity exports before shipping the goods. Exporters must ensure strict consistency and completeness of their data, as any inconsistencies or lack of documentary support may prompt ARCA to treat the registration as unfulfilled, exposing the exporter to penalties under Law 11,683 and potential transfer pricing adjustments.
Additionally, exporters must file Form F. 2670 within 15 days of contract registration to report any comparability differences, as silence within this window is interpreted as an absence of differences.
Read a July 2026 report (Spanish) prepared by the KPMG member firm in Argentina