Argentina has introduced significant structural changes to its Transfer Pricing regime, reshaping thresholds, documentation triggers, and compliance obligations for multinational enterprises. These changes materially affect who must prepare Transfer Pricing documentation, which regime applies, and how disclosures are made.
If your group has cross-border related-party transactions involving Argentina, these updates are not optional reading — they directly influence audit exposure, filing scope, and compliance costs.
This article distills the changes into clear, practical insights so decision-makers can act with confidence.
Why These Transfer Pricing Changes in Argentina Matter
Argentina’s tax authority has recalibrated its Transfer Pricing framework to capture a wider economic footprint while modernizing compliance mechanics. The intent is clear:
👉 focus resources on material transactions while tightening transparency and digital reporting.
For multinational groups, this means:
Re-evaluating whether you fall under the general, simplified, or master file regime
Confirming whether previously exempt entities are now in scope
Adjusting internal reporting systems to meet updated thresholds
Ensuring Transfer Pricing documentation remains defensible under scrutiny
Expanded Thresholds Under the General Transfer Pricing Regime
One of the most impactful changes is the substantial increase in income and transaction thresholds under the general Transfer Pricing regime.
What Changed?
- The total income threshold for mandatory application of the general regime has increased sharply.
- The related-party transaction thresholds (including dealings with non-cooperative or low-tax jurisdictions) have been significantly raised — both at aggregate and individual transaction levels.
Why This Matters
While fewer smaller entities may now fall into the general regime, those that do are expected to meet higher documentation standards. Tax authorities are prioritizing quality and economic substance, not just filing.
Revised Master File Applicability Rules
Argentina continues to require a Master File for qualifying multinational groups, but the transaction-based trigger has been updated.
Key implications:
- Consolidated group revenue thresholds remain aligned with global standards
- The related-party transaction threshold for Master File reporting has been revised
- Groups previously preparing only local documentation may now be drawn into group-level disclosures
- Strategic takeaway: Multinationals should reassess whether Argentine operations now trigger Master File alignment, especially where centralized pricing policies are in place.
Major Expansion of the Simplified Transfer Pricing Regime
Argentina has materially broadened the simplified regime, increasing both eligibility limits and transaction thresholds.
What This Means in Practice
- More taxpayers can now qualify for simplified compliance
- Transaction thresholds under the simplified regime have been aligned upward with the general framework
- However, simplified does not mean risk-free — documentation must still support arm’s length pricing
Caution: Many taxpayers assume simplified regimes reduce audit risk. In Argentina, inadequate economic support remains a common audit trigger, even under simplified filings.
Changes to “No-Transaction” Transfer Pricing Filings
The procedure for filing Transfer Pricing declarations where no related-party transactions exist has been revised.
Why this matters:
- Formal confirmation requirements have changed
- Incorrect or outdated filing approaches can now result in procedural penalties
- Groups must ensure consistency between accounting records, tax returns, and Transfer Pricing disclosures
Parallel Compliance Shift: Digital Fiscal Controller Reporting
Alongside Transfer Pricing changes, Argentina has enhanced its digital tax reporting infrastructure.
Registered taxpayers and exempt entities must now:
- Submit digital audit trail reports
- File monthly summary transaction reports
- Meet strict submission timelines following each reporting period
While not a Transfer Pricing rule per se, this system strengthens data cross-verification, increasing the likelihood that Transfer Pricing positions are tested against transactional records.
Practical Impact on Transfer Pricing Risk in Argentina
These regulatory updates collectively signal:
- Increased reliance on data-driven audits
- Less tolerance for informal or template-based Transfer Pricing studies
- Greater emphasis on transaction materiality and consistency
- Heightened exposure where documentation does not align with actual conduct
For multinational enterprises, Transfer Pricing in Argentina is no longer just an annual exercise — it is an ongoing compliance and governance issue.
How TransferPricing.report Can Help
At TransferPricing.report, we help multinational groups navigate Argentina Transfer Pricing with clarity and confidence.
Our support includes:
- Argentina-specific Transfer Pricing studies
- Regime eligibility assessment (general vs simplified vs Master File)
- Robust benchmarking aligned with local authority expectations
- Audit-ready documentation and defense support
- Practical guidance tailored to your business model
Final Thought: Don’t Treat These Changes as Administrative
Argentina’s updated Transfer Pricing framework is strategic, not cosmetic. Groups that act early gain certainty. Those that delay often face audits, penalties, and forced adjustments.
- Planning cross-border transactions involving Argentina?
- Unsure whether your current Transfer Pricing documentation still holds up?
- Speak with our Transfer Pricing specialists today and turn compliance into control.
This is general information only and not professional advice. Consult a professional before acting.
