Argentina Transfer Pricing Documentation Requirements
Argentina requires a local transfer pricing report from taxpayers whose related-party transactions pass set thresholds, and a Master File from larger groups, filed digitally through dedicated forms in the sixth month after year-end. The report is certified by a public accountant and lodged through Form 4501.
Requirements at a glance
| Requirement | Threshold | Deadline | Deadline type | Language | Penalty |
|---|---|---|---|---|---|
Master File Required | Group consolidated revenue > ARS 4bn and foreign related-party transactions > ARS 3m aggregate or ARS 300,000 individually | Sixth month after fiscal year-end | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. Once requested, it must be provided within 15 days. | ES | Yes (general late-filing fines; elevated audit-risk classification) |
TP report Forms 2668 / 4501
Required | Total foreign related-party transactions > ARS 30m (or single transaction over the stated limit) | Sixth month after fiscal year-end | Submission deadline The documentation must be filed with the tax authority by the date shown. | ES | Yes (ARS 10,000, rising to ARS 20,000 for foreign-owned entities) |
CbC report Required | Group revenue ≥ EUR 750m | 12 months after fiscal year-end | Submission deadline The Country-by-Country report is filed by the group's ultimate parent entity; a local notification identifying the reporting entity is filed separately. | — | Yes |
Calculate your exact Argentina deadline
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Scope of the documentation obligation
A local transfer pricing report must be prepared and filed where a taxpayer’s total transactions with foreign related parties exceed ARS 30 million in the year, or where a single transaction exceeds the stated limit. The Master File applies to larger groups, requiring both that the group’s consolidated annual revenue exceed ARS 4 billion in the prior fiscal year and that transactions with foreign related parties exceed ARS 3 million in aggregate or ARS 300,000 individually. The documentation is produced within 15 days of a request, and the report and forms are filed in the sixth month after the fiscal year-end.
Distinctive features of the Argentine regime
The defining feature of the Argentine regime is its digital filing architecture, built on two annual forms. Form 2668 captures transactions with related parties, with entities in low-tax or non-cooperative jurisdictions, and import and export transactions with third parties, while Form 4501 carries the digital filing of the transfer pricing study together with a certified public accountant’s certification, so the study itself is lodged rather than merely held. Penalties combine general late-filing fines with a documentation-specific fine of ARS 10,000, rising to ARS 20,000 for foreign-owned entities, and non-compliance can also lead to a higher audit-risk classification. A separate substantiation requirement applies to import and export transactions routed through an international intermediary, where the local entity must prove the intermediary’s remuneration. There is no safe harbour.
Benchmarking and comparables
There is no specific requirement on the geographic source of comparables, but the selected companies should have publicly available information, with audited financial statements in Spanish or English, and the tax authority has sought that level of reliability in audit. A single-year analysis is required for the local taxpayer, while multi-year data may be used for the comparables where justified. A fresh benchmarking search is recommended every year, although a reasonable financial update is accepted. The general limitation period is five years for registered taxpayers, beginning on 1 January following the year the return is due, extending to ten years for unregistered taxpayers.
Frequently asked questions
Is the Argentine transfer pricing study filed or only held?
It is filed. The study is lodged digitally through Form 4501 together with a certified public accountant's certification, alongside Form 2668 capturing the related-party and intermediary transactions.
This guide is an informational research aid prepared by Comp-Press and is not tax or legal advice. Transfer pricing rules change; verify current requirements before relying on them for filing.