RG 5903/2026: Key Changes to Transfer Pricing

ARCA Resolution General 5903/2026 replaces the transfer pricing regime and consolidates the rules applicable to international transactions into a single regulation. It substantially raises the thresholds that trigger reporting and documentation requirements, but this relief does not apply to the current fiscal year and coexists with obligations that do not depend solely on transaction amounts.

RG 5903 2026 cambios clave en precios de transferencia

What You Need to Know in 30 Seconds

Topic Main rule
Publication
Published in the Official Gazette on September 30, 2026. Replaces RGs 4717, 4733, 4759, 5010, and 5798.
Effective date
Applies to fiscal years beginning on or after October 1, 2026. For companies with December year-ends, the first covered fiscal year is 2027.
F. 2668
More than ARS 7.5 billion in imports and exports of goods with independent parties, or more than ARS 1.5 billion in aggregate or ARS 300 million per transaction for transfer-pricing transactions.
Transfer Pricing Study
More than ARS 3 billion in aggregate or ARS 600 million per transaction. Also required if the company files Form 2668 and its group is required to file a Country-by-Country Report
Master File
Groups with consolidated revenue above ARS 500 billion and related-party transactions with foreign affiliates exceeding the Study thresholds.
Due dates
Form 2668, the Study, and Form 2672: seventh month after year-end. Master File: twelfth month.
Low-value-adding services
5% margin: minimum when the local entity is the provider, maximum when the foreign related party is the provider. Conditions apply.
Simplified regime
Form 2672 replaces Form 2668 and the Study in three cases. Not available to groups required to file a Country-by-Country Report.
Annual updates
Adjusted annually based on the CPI. The first adjustment applies to fiscal years beginning on or after January 1, 2028.

When Does It Apply, and What Happens to the Current Fiscal Year?

The resolution was published in the Official Gazette on September 30, 2026, and became effective that day, but its provisions apply to fiscal years beginning on or after October 1, 2026 (Article 75). RGs 4717, 4733, 4759, 5010, and 5798 are repealed, although they remain applicable to fiscal years that began before that date (Article 74).

In practice:

Fiscal year Applicable regime Filing
Jan. 1–Dec. 31, 2026
Previous regime, using the thresholds under RG 5798/2025.
In 2027, under the previous regime’s deadlines.
Oct. 1, 2026–Sept. 30, 2027
RG 5903/2026 (first covered fiscal year)
April 2028
Jan. 1–Dec. 31, 2027
RG 5903/2026
July 2028

If your company’s fiscal year ends in December, the filing you prepare in 2027 remains subject to the previous thresholds,
which are significantly lower. The new amounts apply to 2027 transactions.

What Changes Under RG 5903/2026?

The most visible change concerns the monetary thresholds. The previous and new thresholds are shown below:

Item Previous regime (RG 5798/2025) RG 5903/2026
Form 2668: imports and exports of goods with independent parties.
$500 M
$7.500 M
Form 2668: transfer-pricing transactions (aggregate / per transaction.
$150 M / $15 M
$1.500 M / $300 M
Transfer Pricing Study (aggregate / per transaction)
$150 M / $15 M
$3.000 M / $600 M
Master File: group consolidated revenue
$100.000 M
$500.000 M
Simplified regime: foreign trade with independent parties
Between ARS 500 million and ARS 3 billion
Between ARS 7.5 billion and ARS 45 billion

In addition to changing the amounts, the regulation:

  • Consolidates rules previously spread across five resolutions into one text and retains Forms 2668, 2672, 2673, and 4501.
  • Updates the amounts annually based on the CPI, using the change from October to October of the previous year. The first update applies to fiscal years beginning on or after January 1, 2028.
  • Clarifies the comparability analysis: objective criteria for accepting or rejecting comparables, exclusion of entities reporting operating losses unless justified, and quantified, substantiated adjustments in the Study.
  • Allows the foreign party to be tested instead of the local entity in limited circumstances.
  •  Provides detailed rules for related-party services, financial transactions, international intermediaries, and commodity exports.
  • Prohibits downward transfer-pricing adjustments from being reflected in the income tax return.

In all cases, transactions must be analyzed according to their economic substance, including the functions performed, assets used, and risks assumed.

When Must Form 2668 Be Filed?

Form 2668 is the information return for international transactions. Article 58 establishes two thresholds:

  • Foreign trade with independent parties: imports and exports of goods exceeding ARS 7.5 billion during the fiscal year.
  • Transactions subject to transfer-pricing rules (with foreign related parties or entities in non-cooperative jurisdictions or jurisdictions with low or no taxation): more than ARS 1.5 billion in aggregate or more than ARS 300 million per transaction.

For the second category, exceeding either threshold is sufficient: a single transaction above ARS 300 million triggers filing even if the annual total is below ARS 1.5 billion. Anyone meeting either threshold must report all international transactions, including those with independent parties and those subject to transfer-pricing rules.

There is also a rule for taxpayers who filed Form 2668 “with activity” in either of the two previous tax periods. If they do not exceed the thresholds in the current year or have no transactions to report, they must file a “no activity” return. After two consecutive periods filing in this manner, they are exempt from filing until the triggering conditions arise again.

Transfer Pricing Study: Two Ways to Trigger the Requirement

Article 60 requires a Study in two situations:

  • Based on transaction amounts: covered transactions exceed ARS 3 billion in aggregate during the tax period or ARS 600 million per transaction.
  • Because the company belongs to a group required to file a Country-by-Country Report: if the company must file Form 2668 for its transfer-pricing transactions and is also part of a multinational group required to file a Country-by-Country Report (RG 4130), it must submit the Study even if transactions do not reach ARS 3 billion.

For subsidiaries of those groups, therefore, the effective Study threshold is the Form 2668 threshold: ARS 1.5 billion in aggregate or ARS 300 million per transaction.

Example. A company with a December year-end records ARS 2 billion in transactions with foreign related parties in 2027,
with no individual transaction exceeding ARS 300 million. It must file Form 2668 because the total exceeds ARS 1.5 billion.
It does not have to file the Study because the total is below ARS 3 billion, unless its group is required to file a
Country-by-Country Report. In either case, it must retain supporting documentation.

The Study must document how the price was determined, which comparables were used, what adjustments were made, and why the selected method is appropriate. The justification must cover all transactions during the period that fall under the regime; selecting transactions based on random or algorithmic samples is not permitted (Article 38).

The Study is filed together with Form 4501 and must be certified by an independent public accountant or economist, with the signature authenticated by the relevant professional council (Articles 61 and 62).

Master File: Higher Threshold and Simplified Ratification

Companies that transact with foreign related parties and belong to a multinational group must file a Master File when both of the following conditions are met (Article 63):

  • The group’s consolidated annual revenue exceeded ARS 500 billion in the fiscal year preceding the filing year.
  • Transactions with foreign related parties during the period exceed ARS 3 billion in aggregate or ARS 600 million per transaction.

The Master File is attached to Form 2673. If there have been no changes compared with the previous report, the regulation allows it to be replaced with a Ratification Statement.

When Are the Filings Due?

Article 70 sets due dates based on the final digit of the taxpayer identification number (CUIT):

CUIT ending in Form 2668, Study, and Form 2672 (7th month after year-end) Master File (12th month after year-end)
0 or 1
By the 2nd
By the 23rd
2 or 3
By the 3rd
By the 24th
4 or 5
By the 4th
By the 25th
6 or 7
By the 5th
By the 26th
8 or 9
By the 6th
By the 27th

For a fiscal year ending December 31, 2027, Form 2668 and the Study are due in July 2028, while the Master File is due in December 2028. If a due date falls on a holiday or non-business day, it moves to the next business day.

Related-Party Services: An Area to Review

The analysis must consider whether the service is necessary for the business, the parties’ conduct, the conditions under which it is provided, and whether it provides—or is expected to provide—an economic benefit to the party paying for it. The regulation also identifies services that should not be treated as transactions between independent parties, such as certain shareholder costs and duplicated services.

For low-value-adding services, a simplified option avoids the comparability analysis (Article 17). The margin on operating costs and expenses related to the transaction is considered arm’s length if it is:

  • At least 5% when the provider is the local entity.
  • No more than 5% when the provider is the foreign related party.

This option requires all of the following conditions to be met:

  • Low-value-adding services received do not exceed 10% of the local entity’s operating expenses, or services provided do not exceed 10% of its operating revenue.
  • The local tested party does not report an operating loss for the period.
  • The local tested party is not undergoing a business restructuring.

In addition, the service must qualify as low-value-adding (Article 18): it must support the recipient’s core business, not form part of the group’s core activity, not require or create unique and valuable intangibles, and not involve the provider assuming or controlling significant risks.

This is relevant to companies receiving administrative, accounting, financial, or human resources services from abroad. Calling a service one of these things in a contract is not enough; the conditions must be verified.

Other Rules Worth Keeping in Mind

Financial transactions

It must be demonstrated that the lender has the economic and financial capacity to provide the loan and control the risks, and that the borrower can repay principal and interest according to the agreed schedule (Article 20). When implicit group support makes it difficult to find reliable market rates for the borrower, the group’s credit rating may be used as a reference (Article 21). Participation in cash-pooling arrangements must be justified, including the need for the arrangement and the source of the cash surplus (Article 23). Interest is deductible under the terms of Article 85 of the Income Tax Law to the extent that it complies with the arm’s-length principle (Article 25).


International intermediaries

An intermediary is a foreign party that facilitates the purchase and sale of exported or imported goods without taking physical possession of them, regardless of how it is compensated (Article 31). The taxpayer must substantiate the intermediary’s business substance and show that its compensation method matches its functional profile, whether it acts as a sales agent, reseller, or trader (Article 32). If the compensation does not match the profile, a comparability analysis is required: compensation is considered arm’s length when it falls within the interquartile range; if it exceeds the upper limit, the median is used (Article 33).


Commodity exports

For soybeans, corn, bread wheat, soybean and sunflower oils, and soybean pellets and meal, the exporter may use as a minimum value the official FOB price published by the Secretariat of Agriculture, Livestock and Fisheries for the date the sale is closed and the relevant shipment period (Article 41).


Downward adjustments

Transfer-pricing adjustments that reduce prices, consideration, or margins may not be reflected in the income tax return, unless they arise from a mutual agreement procedure under a tax treaty to avoid double taxation (Article 48).


Foreign tested party

The general rule is to test the local entity. The foreign party may be tested when its functions, assets, and risks are less complex and the transaction is a service received, a transaction involving an international intermediary, or imports or exports of goods representing less than 2% of operating costs or sales, respectively. Reliable information about its profitability must also be available, and the transaction must not involve unique or valuable intangibles (Articles 5 and 6).

How Does the Simplified Regime Work?

Taxpayers required to file Form 2668 or the Study may replace them with Form 2672 if they fall into one of the three cases listed in Article 64:

  1. Smaller companies. Annual revenue below the cap for the medium-sized company, Tier 1 category; no losses or restructurings in the current year or the two preceding years; no loans with foreign related parties; related-party services not exceeding 1% of revenue; and royalties, licenses, or research and development agreements not exceeding 1% of that cap.
  2. Low impact of related-party transactions. International transactions with related parties do not exceed 2.50% of total revenue, with royalties, licenses, or research and development at no more than 0.50%; no losses or restructurings in the current year or the two preceding years; and no transactions with international intermediaries.
  3. Foreign trade with independent parties. Imports and exports of goods with independent parties exceed ARS 7.5 billion but are below ARS 45 billion during the fiscal year.

The regime is unavailable to members of a multinational group required to file a Country-by-Country Report in any jurisdiction and to entities required to file a Master File (Article 65).

Choosing the simplified regime does not eliminate the obligation to retain supporting records. ARCA may request the Study when transactions exceed ARS 3 billion in aggregate or ARS 600 million per transaction (Article 69). In that case, the taxpayer has 45 days from notification to submit the Study together with the working papers.

Documentation and Penalties

The obligation to retain supporting documentation does not depend on filing thresholds. Importers and exporters dealing with independent parties must retain, among other items, counterparty information, transaction descriptions, banking documentation (including SWIFT records), and sources for the international prices used (Article 51). Those dealing with related parties or entities in non-cooperative jurisdictions or jurisdictions with low or no taxation must retain working papers supporting price setting and comparability criteria (Article 52). All documentation must be available to ARCA at the taxpayer’s registered tax domicile (Article 71).

Noncompliance is subject to penalties under Law 11,683 and may affect the taxpayer’s category in the Risk Profile System (SIPER) (Article 72).

Common Mistakes When Analyzing the New Regime

  1. Applying the new thresholds to the current fiscal year


    The amounts under RG 5903/2026 apply to fiscal years beginning on or after October 1, 2026. A fiscal year ending December 31, 2026, is assessed using the previous thresholds.

  2. Looking only at the annual total

    A single transaction may exceed the threshold even if the annual total does not. Both aggregate and individual thresholds must be reviewed.

  3. Assuming no Study is required below ARS 3 billion

    If the group is required to file a Country-by-Country Report, the Study is required once the Form 2668 thresholds are met. Supporting documentation must be retained in all cases.

  4. Confusing related-party status with share ownership


    A related-party relationship is not limited to a parent or subsidiary relationship. It can also exist where there is a sole or principal supplier or customer relationship—meaning transactions are so significant that their absence would halt the activities of the local entity or its foreign counterparty (Article 3).

  5. Documenting prices only after year-end


    A comparability analysis requires information about contracts, commercial terms, functions, assets, risks, and comparables. Reconstructing all of this at year-end can lead to inconsistencies.

  6. Assuming every intragroup service is deductible


    The regulation requires an analysis of the service’s necessity, usefulness, and economic substance, and excludes certain shareholder costs and duplicated services.

  7. Automatically applying the 5% margin


    The 5% margin for low-value-adding services is not a general rate for all intragroup services. It is an option subject to the requirements of RG 5903/2026.

What Should a Company Review Now?

At a minimum, it is advisable to identify:

  1. The fiscal year start date, to determine which regime and thresholds apply.
  2. All transactions with foreign related parties and with entities in non-cooperative jurisdictions or jurisdictions with low or no taxation.
  3. Imports and exports with independent parties.
  4. Intragroup services, royalties, licenses, and financial transactions.
  5. Individual and aggregate amounts by transaction type.
  6. Whether the group is required to file a Country-by-Country Report and whether the Master File threshold is met.
  7. The contracts, comparables, and methodology supporting the agreed prices.
  8. The filing calendar based on the final digit of the CUIT.

If your company conducts international transactions with related parties, we can help determine which obligations arise under RG 5903/2026 and what documentation you should have ready to support your transfer-pricing analysis.

Frequently Asked Questions

Do the new thresholds apply to fiscal year 2026?

Only if the fiscal year began on or after October 1, 2026. Fiscal years that began before that date remain subject to the previous regime and thresholds, even if the filing is made in 2027.

Do I have to file a Transfer Pricing Study if I do not exceed ARS 3 billion?

Yes, in two cases: if any individual transaction exceeds ARS 600 million, or if the company is required to file Form 2668 for it’s transfer-pricing transactions and its group must file a Country-by-Country Report.

Must documentation be retained even if I do not have to file anything?

Yes. Articles 51 and 52 require taxpayers to retain records and working papers supporting transactions and price setting, regardless of the filing thresholds.

When are the filings due?

Form 2668, the Study, and Form 2672 are due in the seventh month after fiscal year-end, between the 2nd and 6th depending on the final digit of the CUIT. The Master File is due in the twelfth month, between the 23rd and 27th.

Does the simplified regime eliminate the Transfer Pricing Study?

Taxpayers that properly elect the Simplified International Transactions Regime do not file the Study or Form 2668. ARCA may nevertheless request the Study when transactions exceed ARS 3 billion in aggregate or ARS 600 million per transaction, with 45 days to submit it. Groups required to file a Country-by-Country Report and entities required to file a Master File may not elect the regime.

How are the amounts adjusted?

Every year, based on the change in the CPI from October to October of the previous year. The first adjustment applies to fiscal years beginning on or after January 1, 2028.

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