Prezzi di trasferimento in Argentina: nuove norme per le società di proprietà straniera

Any Argentine company that buys from, sells to or pays fees to a related company abroad has to think about transfer pricing. The prices used in those intercompany transactions must match what independent parties would agree, and the tax authority checks that through information returns, studies and audits.

ARCA has now replaced the regime that governed those obligations. General Resolution 5903, published in the Official Gazette on September 30, 2026, applies to fiscal years beginning on or after October 1, 2026, and repeals earlier resolutions including General Resolutions 4717 and 5010. For many small foreign-owned companies the headline is good news: the thresholds that trigger the heavier filings are now much higher and will be updated every year.

Who transfer pricing rules apply to

The rules cover transactions between an Argentine taxpayer and foreign related parties, as well as transactions with entities in low or no-tax jurisdictions. Some import and export operations with independent parties also carry information duties when they exceed set amounts.

In practice, the rules matter for situations such as these:

• An Argentine SAS owned by a foreign parent that pays for management, software or technical services.
• A local company importing goods from a related supplier abroad, or exporting to a related distributor.
• Royalties paid to a foreign company that owns the brand or technology.
• Intercompany loans between the local company and its shareholders or affiliates.

Higher thresholds, indexed every year

The resolution raises the amounts that trigger each obligation and adds an annual update by consumer price inflation, a feature the previous regime lacked. According to professional analyses of the new text, the thresholds are as follows:

For reference, the Form 2668 threshold was ARS 500 million under the previous rules, so a large group of small importers and exporters drop out of that filing. Below the thresholds, the arm’s length principle still applies: you simply have lighter documentation duties.

Other changes worth knowing

Beyond the thresholds, the resolution updates several technical criteria that had caused disputes in audits and before the courts:

• Companies that import or export on behalf of third parties no longer report those operations; the owner of the goods does.
• The test that treats a sole or principal client or supplier as a related party is narrowed: it now applies only if losing those transactions would mean ceasing the activity.
• Analyses can be done on an aggregate or segmented basis, and must include transactions with no consideration.
• A foreign party can be used as the tested party, under conditions, when its functions, assets and risks are less complex.
• Low value-adding services get a simplified option with a 5% profit margin and no comparability analysis, subject to requirements.
• For intangibles, legal ownership alone does not entitle a company to the profits; what counts is who performs the functions.
• Downward adjustments are not allowed unless they result from a mutual agreement procedure under a double tax treaty.

What a small foreign-owned company should do now

1. List every flow with related parties: services, royalties, goods, loans and reimbursements.
2. Check whether the amounts for your first fiscal year starting on or after October 1, 2026 cross any of the new thresholds.
3. Put intercompany agreements in writing and document how prices are set, even if you are below the thresholds.
4. If you pay for routine support services from abroad, assess whether the simplified 5% margin option fits.
5. Review the structure itself: the right setup for a subsidiary or a holding company can make intercompany flows much easier to defend.

Transfer pricing is part of broader planning, so it is worth reading alongside our guide to pianificazione fiscale per le imprese di proprietà straniera and our overview of accounting and reporting duties. If you want a second look at your intercompany setup, contatta SAXIA.

How the new rules affect common setups

Most small foreign-owned companies in Argentina fall into a few typical patterns. Here is how the new framework tends to play out for each of them:

Domande frequenti

If my company is below every threshold, can I ignore transfer pricing?

No. The thresholds define which returns and studies you must file, but intercompany prices must still be at arm’s length. In an audit, the tax authority can adjust prices that do not meet that standard even if no study was required.

When does the new regime start for my company?

It applies to fiscal years beginning on or after October 1, 2026. For a company with a calendar-year fiscal year, that means the fiscal year starting January 1, 2027. Fiscal years that began before October 1, 2026 remain under the previous rules.

Do the thresholds stay fixed?

No. One of the main changes is that thresholds are updated every year according to consumer price inflation, so the amounts that apply to a given year should always be checked before filing.

This article is for general information only and does not constitute legal or tax advice. Thresholds are taken from professional analyses of General Resolution 5903 and are updated annually; confirm current amounts with ARCA or your advisor before filing.