On 30 September 2026, the Argentine Revenue and Customs Control Agency (ARCA) published Resolution General 5.582/2026, amending the regulatory framework for transfer pricing and foreign trade operations under Law 11.683 and the Income Tax Law. The reform, effective for fiscal years beginning on or after 1 January 2027, introduces a simplified compliance tier for small and medium enterprises (SMEs) with cross-border related-party transactions below 2% of total revenue, while simultaneously tightening documentation and transparency obligations for multinational groups and foreign intermediaries operating in Argentina.
Key Takeaways
- SME Safe Harbor Introduced: Qualifying SMEs—defined as entities with annual revenue under ARS 50 billion—are exempt from the full master file and local file requirements if their aggregate cross-border related-party transactions do not exceed 2% of total turnover, replacing the previous one-size-fits-all regime.
- Enhanced Intermediary Disclosure: Foreign intermediaries (commission agents, distributors, and service providers) must now report the ultimate beneficial owner and the full transaction chain to ARCA quarterly, targeting base erosion via conduit structures in low-tax jurisdictions.
- Risk-Based Audit Recalibration: ARCA will deploy advanced analytics to prioritize audits on high-value intangibles, financial transactions, and business restructurings, while reducing routine verification of low-risk commodity trade, aligning resources with BEPS Action 8-10 outcomes.
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.
Source: Read Official Announcement