Argentina: local rules

Argentina has no stand-alone transfer pricing act. The rules sit in the Income Tax Law (Ley 20.628, consolidated text 2019 by Decreto 824/2019): article 9 for imports and exports, article 16 for permanent establishments and article 17 for transfer pricing, with related parties defined in article 18 and non-cooperating and low or no tax jurisdictions in articles 19 and 20. Dealings with related parties abroad are treated as arm's length only if their terms follow normal market practice between independent parties, and if not they are adjusted under article 17. Dealings with non-cooperating or low or no tax jurisdictions are never treated as arm's length. The regulation is Decreto 862/2019 (mainly articles 14, 24, 25 and 29 to 55). The tax authority is ARCA, which replaced AFIP, and since 30 September 2026 the filing rules are in General Resolution 5903/2026, which replaces RG 4717/2020 for fiscal years that start on or after 1 October 2026.

A taxpayer above the limits files a Transfer Pricing Study (the local file, certified by an independent accountant and sent with Form F. 4501), the sworn return Form F. 2668, and, for large groups, a Master File (Form F. 2673) or a ratification note. For fiscal years that started before 1 October 2026 (RG 4717): the study is due if related-party or tax-haven transactions top ARS 150m in total or ARS 15m for one item, Form F. 2668 has the same limits plus ARS 500m for imports and exports with independent parties, and the Master File needs group revenue above ARS 100,000m and related-party transactions above ARS 150m. For years starting on or after 1 October 2026 (RG 5903): the study needs ARS 3,000m in total or ARS 600m for one item, Form F. 2668 needs ARS 1,500m in total, ARS 300m for one item or ARS 7,500m of independent trade, and the Master File needs group revenue above ARS 500,000m and related-party transactions above ARS 3,000m. All these amounts will be indexed to October inflation from fiscal years starting on 1 January 2028. Due dates follow the last digit of the CUIT: the study and Form F. 2668 are due in the 6th month after year end on days 23 to 27 under RG 4717, and in the 7th month on days 2 to 6 under RG 5903, while the Master File is due in the 12th month on days 23 to 27 under both; this site shows the earliest day. Smaller taxpayers that pass the tests in RG 5903 art. 64 can use the simplified Form F. 2672 instead, and all records must be kept at the tax address.

Article 17 of the law lists five methods: comparable price between independent parties, resale price, cost plus, profit split and transactional net margin. Other methods are allowed for unique assets with no comparables (Decreto 862/2019 art. 29(f)). There is no fixed order, since the most appropriate method is the one that best shows the economic reality, judged by fit with the business, data quality, comparability and the number of adjustments needed (art. 30), but the comparable price method is the one for quoted goods (art. 31). With two or more comparables the median and interquartile range are worked out, and a result inside the range is accepted while one outside it is replaced by the median (art. 42, reworded by Decreto 767/2025 for years closing from 29 October 2025). RG 5903 does not accept price averages for the tested transactions or random samples of them, and in principle excludes loss-making comparables (arts. 8, 38 and 40). It also offers an optional 5% mark-up on costs for low value-added services, if conditions are met (arts. 17 and 18). A downward adjustment cannot be taken in the return unless it comes from a mutual agreement procedure (art. 48).

Failing to file the related-party detail return on time is fined ARS 11m, or ARS 22m for companies, and failing to give data requested for the control of international operations, or to keep the price evidence, is fined up to ARS 35m (Ley 11.683 arts. 39 and the articles after art. 38). A missing, late or poor CbC report is fined ARS 45m to ARS 67.5m, and failing to report group membership ARS 6m to ARS 15m. Tax underpaid because of an adjustment is fined 100% of the tax (art. 45), or 200% when the shortfall comes from dealings with any person or entity abroad. Repeat offences raise these to 200% and 300%. Fraud is fined 2 to 6 times the tax (art. 46). A late income tax return is fined ARS 440,000 for companies (art. 38). The amounts were raised by Law 27.799 (published 2 January 2026), and non-compliance also raises the taxpayer's audit risk score (SIPER).

Argentina has not enacted Pillar Two. No income inclusion rule, undertaxed profits rule or domestic minimum top-up tax is in force, and the only proposal found is a 2023 member's bill (expediente 3978-D-2023) with no sign of passage. So there is no GloBE filing or payment deadline for Argentine entities. Check again before relying on this, because several countries are still adding rules.

Interest on loans from related parties is deductible only up to the larger of an annual amount set by the Executive or 30% of net profit before interest and depreciation, with the excess carried forward for 5 years (Income Tax Law art. 85 a). Royalties for trademarks and patents owned by foreign parties are deductible only up to limits set by the regulation (art. 92 m; Decreto 862/2019 art. 229). Exports of quoted goods through an international intermediary must be registered, and if not, the income is set at the quotation on the loading day (art. 17; RG 5872/2026). No unilateral advance pricing agreement procedure was found; relief comes from mutual agreement procedures under the tax treaties. Argentine entities of any multinational group must register the group with ARCA each year (Form F. 8096), even if the group is below the CbC limit.