Argentina master file and local file requirements (2026)

What are Argentina's latest transfer pricing rules?

The thresholds moved, and nothing else did. A resolution published on 16 December 2025^[1] raised the local file trigger from ARS 3,000,000 of related party transactions to ARS 150,000,000, and the single transaction trigger from ARS 300,000 to ARS 15,000,000. The master file trigger went from ARS 4,000,000,000 of group revenue to ARS 100,000,000,000. The new figures apply to fiscal periods closing on or after 31 October 2025.

The underlying parameters come from a decree published on 28 October 2025^[2], which set the documentation threshold at ARS 150,000,000. Peso inflation is what drives these jumps, so expect the numbers to move again.

One source conflict is worth flagging. The consolidated text of the 2020 documentation resolution shows ARS 1,500,000,000 in an amendment note against ARS 150,000,000 in the body of the same article. This page records ARS 150,000,000, which is what the October 2025 decree sets. Confirm the figure with your Argentine adviser before you scope out of filing on it.

The tax authority also changed its name. ARCA, the Agencia de Recaudación y Control Aduanero, replaced AFIP under a decree published on 25 October 2024^[3] that names ARCA the legal successor. Guidance that still says AFIP points at the same rules.

Who has to file transfer pricing documentation in Argentina?

Any Argentine subsidiary, branch or permanent establishment that transacts with a related party abroad. The obligation sits on the local entity, so a foreign parent carries the filing risk through its Argentine presence rather than directly.

There is no single ownership percentage behind the related party test. The income tax law sets a common direction and control standard, and the implementing decree lists fourteen relationship tests^[4], running from majority capital ownership through shared directors to dependence on a sole supplier. Two companies with no equity link between them can still be related.

A transaction with a counterparty in a low tax or non cooperative jurisdiction is presumed not to be at arm's length. That presumption pulls it into the regime even where nobody owns anybody.

What are Argentina's master file requirements?

A master file is due when group consolidated revenue exceeded ARS 100,000,000,000 in the prior year and cross-border related party transactions exceed ARS 150,000,000 in total or ARS 15,000,000 individually. It goes in on Form F. 2673 by the twelfth month after the fiscal year closes, on a schedule keyed to the last digit of the entity's tax identification number.

The content follows the standard international list: group structure, business lines, intangibles, intercompany financing, and the group's financial and tax positions. The December 2025 resolution created Form F. 2673, so a group filing a master file in Argentina for the first time is filing on a form that did not exist two years ago.

What are Argentina's local file requirements?

The local file, the Estudio de Precios de Transferencia, is due once related party transactions exceed ARS 150,000,000 in total or ARS 15,000,000 for any single transaction. It is due in the sixth month after the fiscal year closes, on the same tax identification number schedule, and it benchmarks the Argentine entity's own controlled transactions.

Argentina prefers local comparables. A pan-regional benchmarking set that satisfies a neighbouring country will not automatically satisfy ARCA, according to the OECD transfer pricing country profile for Argentina^[5] updated in October 2025.

Does Argentina require country-by-country reporting?

Yes, for groups at or above EUR 750,000,000 of consolidated revenue. Argentine constituent entities register their status on Form F. 8096 within the third month after the fiscal year closes. The report itself, Form F. 8097, is due by the last business day of the twelfth month after the ultimate parent's year end.

A second notice, confirming that the report was filed abroad, is due by the last business day of the second month after the report deadline. The country-by-country rules^[6] have been in force since 2017 and were not touched by the 2025 threshold changes. Groups below EUR 750,000,000 are exempt.

Which forms does the tax authority require?

Five, and each has its own trigger. The informative return and the local file travel together. The master file and the two country-by-country forms are separate submissions.

When is Argentina transfer pricing documentation due?

Deadlines run off the fiscal year close and are staggered by the last digit of the tax identification number. For the December year end that most multinational subsidiaries run, the local file and the informative return land in June and the master file in December of the following year.

ARCA issues one-off extensions in some cycles, so check the current year's notices before you plan around these dates.

What language must the documentation be in?

Spanish. A supporting document in another language needs a Spanish translation prepared by a sworn public translator before it can go in with the study. Budget the translation time: it is the step that most often pushes a June filing into a late one.

Is there a simplified regime for smaller taxpayers?

Yes, an optional one on Form F. 2672 for low risk taxpayers. It is closed to anyone who files a master file and to any member of a country-by-country reporting group, so in practice it serves locally owned businesses rather than subsidiaries of large multinationals.

The December 2025 resolution also reports updated income bands for the regime. Those amounts are not confirmed from a primary source, so this page does not state them.

What are the penalties for getting Argentina transfer pricing wrong?

Fines for a missed or late filing are not confirmed for 2026, and this page will not guess at them. A law published on 2 January 2026 replaced the fine amounts in the tax procedure law, and the new transfer pricing figures could not be verified against the official consolidated text. The older published figures are stale.

What is certain is the exposure. Failing to file is a statutory offence, and ARCA can apply fines on top of substantive transfer pricing adjustments to taxable income. A secondary report says the same January 2026 law shortened the general limitation period for compliant filers from five years to three. That is flagged here rather than asserted, because it is not confirmed from a primary source.

Can you get an advance pricing agreement in Argentina?

Not in practice. Advance pricing agreements are provided for in the law but remain unregulated, with no programme running, according to the OECD country profile dated October 2025. The mutual agreement procedure under Argentina's tax treaties is the route that works for relieving double taxation.

Argentina is not an OECD member. It is an accession candidate and a member of the Inclusive Framework, so it has adopted the three tier structure of master file, local file and country-by-country report while treating the OECD guidelines as interpretive guidance rather than binding law.

How do multinationals comply with Argentina transfer pricing rules?

The sequence for a foreign parent with an Argentine entity:

1. Add up every cross-border transaction the Argentine entity had with the group and test it against ARS 150,000,000 in total and ARS 15,000,000 individually.
2. Check group consolidated revenue against ARS 100,000,000,000 to see whether a master file is due as well.
3. Build the benchmarking study on local comparables rather than a regional set.
4. Book the sworn translation of anything written in another language.
5. File the informative return and the local file in month six, on your tax identification number's day.
6. File the master file in month twelve, and the country-by-country forms on their own track if the group is at or above EUR 750,000,000.

How we help with Argentina transfer pricing

Argentina files rather than retains, so a missed deadline is visible to ARCA on day one instead of at audit. We scope the entity against the new thresholds, build the benchmarking study on local comparables, draft the master file and the local file, and file them on the schedule your tax identification number falls on. See how our transfer pricing software works.

Book a demo to find out whether your Argentine entity is still in scope under the 2026 thresholds.