Global transfer pricing guide

Argentina Transfer Pricing Policy

How Argentina’s ARCA — the successor to AFIP — applies transfer pricing rules, and what the Argentine reporting regime requires.

Revenue authority
ARCA
Region
South America
Arm’s-length standard
Applied to related-party dealings
Figures on this page
Read in the primary source

Introduction to Transfer Pricing in Argentina

Argentina applies the arm’s-length principle to transactions with related parties abroad under its income tax law. The administration was reorganised by Decree 953/2024, which dissolved AFIP and created ARCA as its legal successor — so guidance, resolutions and correspondence carry different agency names either side of that change while addressing the same rules.

The Argentine regime is heavy on structured reporting. Related-party transactions are reported through prescribed regimes and studies filed with the authority, which means the analysis is submitted rather than merely held. A jurisdiction where the study itself is filed is one where the quality of the study is visible immediately.

Argentina also has a distinctive rule for exports and imports routed through international intermediaries, aimed at commodity flows that pass through a related or low-substance trader. That rule has no counterpart in most of the jurisdictions in this guide and it changes how a commodity chain has to be documented.

The statutory position

  • ARCA states on its own institutional page that Decree 953/2024 dissolved the Administración Federal de Ingresos Públicos (AFIP) and created the Agencia de Recaudación y Control Aduanero, that "ARCA es la continuadora jurídica de la AFIP", and that it comprises the Dirección General Impositiva (DGI) and the Dirección General de Aduanas (DGA).
  • Its remit, in ARCA’s own words, is the collection of taxes, the control of foreign trade, and taxpayers’ compliance with their obligations in tax, customs and social security matters.

Those references were read in the primary source — arca.gob.ar — on 2026-08-19, and they are quoted because they were read. Legislation is amended and guidance is reissued, so confirm the current text before relying on any of it for a filing position.

Documentation & Regulatory Requirements

Argentine compliance combines a transfer pricing study with prescribed information regimes filed with the authority, plus master file and country-by-country reporting for groups above the relevant thresholds. Because the study is filed rather than retained, its completeness is assessed on receipt.

The intermediary rule for exports and imports means commodity chains need documentation of what the intermediary actually does, not only of the price. Where the intermediary has no real function, the rule looks through to the underlying transaction, and the file has to address that head on.

Thresholds, filing deadlines and penalty amounts are set by general resolution and have been revised repeatedly, including through the agency transition. We confirm the current position against ARCA material for the period in question rather than state a figure here.

The three-tier documentation shape

Almost every regime in this guide organises documentation the way BEPS Action 13 recommended: a master file describing the group, its structure, its intangibles and its financing; a local file describing the local entity’s own controlled transactions and the analysis behind their pricing; and a country-by-country report giving administrations an aggregate view of where the group books revenue, profit, tax and people. That last report is owed only above a size threshold, and the OECD’s agreed figure is EUR 750 million of consolidated group revenue, or a near equivalent amount in domestic currency as of January 2015 (OECD, Action 13 country-by-country reporting (oecd.org)). Each jurisdiction legislated its own local-currency equivalent; those are not repeated on this page, because they were not read from the source.

What we confirm before an Argentina file is signed off

  • Which tiers of documentation are genuinely due for the period in front of us, checked against what ARCA requires now — not against what it required when the last file was written.
  • Whether every intercompany flow has been characterised — the recharge, the guarantee, the seconded employee and the loan are the ones routinely missing from the transaction list.
  • That the paperwork tells one story — agreements, invoices, management accounts and the policy the file sets out, all saying the same thing about the same year.
  • That the local narrative is consistent with what the group has already reported for Argentina anywhere else, because the authority sees both.

Transfer Pricing Methods

Argentina works from the OECD method set and requires the most appropriate method for the transaction, with the additional intermediary rule sitting over commodity flows. Comparables for the Argentine market are difficult, and the file’s credibility depends on how the search was extended and what was adjusted — inflation and currency movement in particular make a prior-year comparable set unreliable in a way that has to be addressed rather than ignored.

The five methods in the OECD framework

Comparable uncontrolled price (CUP)
Takes the price independent parties actually charged each other for the same thing and applies it. Nothing beats it for directness, which is why several administrations state a preference for it, and nothing is harder to find: product, volume, market and contract terms all have to line up before the comparison holds.
Resale price
Starts from the price the related distributor charges an independent customer and works back by an arm’s-length gross margin. Suits a distributor that resells without transforming the goods, and it is sensitive to how the functions actually split — one carrying marketing risk is not comparable to one that does not, whatever the contract says.
Cost plus
Builds the price up from the supplier’s costs plus an arm’s-length mark-up. Used for contract manufacturing, routine assembly and intra-group services. The argument is almost never about the mark-up; it is about which costs belong in the base and whether the cost accounting is consistent year to year.
Transactional net margin (TNMM)
Tests a net-level return — margin on sales, on total costs or on assets — against a set of independent companies with comparable functions. Robust to product mismatches and fragile to comparable selection, so the screening decisions and the adjustments matter more here than the arithmetic does.
Profit split
Divides the combined profit of the controlled transaction between the parties by reference to their relative contributions. Reached for where both sides make unique and valuable contributions, where the operations are so integrated that neither can be priced on its own, or where each shares in economically significant risk.

No method is correct in the abstract. The one that holds up in Argentina is the one whose selection is reasoned on the record — with the alternatives named and rejected for stated reasons — because a method presented without alternatives reads as a default rather than a choice.

Analytical & Compliance Support

A Argentina transfer pricing file is a piece of evidence before it is a piece of compliance, and it is read by someone looking for the gap between what the policy says and what the ledger did. That is the gap we work on first.

What an Argentina engagement covers

  • Transaction mapping and delineation. Every related-party flow into and out of the Argentina entity, characterised and reconciled to the ledger, before any analysis begins.
  • Functions, assets and risks. What the Argentina operation really does, who takes the decisions, and which risks it can actually control. Everything downstream depends on getting this right, and it is the part most files compress.
  • Method selection, reasoned on the record. The method chosen for each tested transaction, with the alternatives considered and the reason each was set aside.
  • Benchmarking you can audit. The search criteria, every screening decision and every comparability adjustment set out in full, so a reviewer reproduces the result rather than building their own.
  • Documentation to ARCA’s expected shape, consistent with the group’s master file and with what has been reported for Argentina elsewhere.
  • Sourcing, stated. Each threshold, deadline and rate in the finished file is checked against ARCA (Agencia de Recaudación y Control Aduanero), the successor to AFIP for the relevant period. Where we cannot confirm a figure, the file explains the mechanism and gives no number.

Advance certainty and dispute resolution

Argentina provides the mutual agreement procedure under its treaty network and a domestic administrative and judicial appeal route. Because the studies are filed, disputes tend to start from the authority’s reading of a document the taxpayer already submitted, which puts a premium on the study being complete when it goes in.

How we work

The fee is agreed in writing before any work starts, and you review the result before anything is filed. Where your Argentina entity sits relative to our offices makes no difference to how the file gets built. If you want to talk it through first, the helpline answers 24 hours a day and there is no obligation attached to a call — contact us or read our transfer pricing service page for what a full engagement includes.

Use Cases by Business Size & Industry

By business size

Owner-managed group
An Argentine company transacting with a foreign affiliate is inside the rules and, depending on size, inside the information regimes. The study is filed, not filed away.
Mid-market group
Several transaction types mean several method choices, all appearing in a study the authority reads on receipt.
Multinational group
Master file and country-by-country reporting engage, and the Argentine study has to be consistent with what the group reported for Argentina.

By industry

Agribusiness and commodity exports
Related-party or intermediated commodity sales sit directly under the intermediary rule, and the trader’s function is the documented question.
Energy and mining
Related-party offtake, services and funding need separate analyses, and the funding terms are examined against a volatile local cost of capital.
Pharmaceuticals and consumer goods
Imported related-party product plus locally funded marketing raises the compensation question inside an inflationary environment.

Read these as starting points rather than categories. The transfer pricing question is set by the group structure and the intercompany agreements, not by what the business sells — so two Argentina companies of the same size in the same sector routinely need completely different files. The sector says where to look; the agreements say what is there.

Other South America guides

Every jurisdiction here gets its own page. Regional summaries hide exactly the differences that decide a file, so there is no shared South America template behind these.

Related Legal Quotient pages

This page orients you. The links below are the practice itself — what an engagement involves, what it costs, and the neighbouring cross-border questions an Argentina position tends to pull in with it.

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Cross-border tax case studies

Case study 1

Commodity export chain documented against the intermediary rule

An Argentine producer sold through a trading company abroad and had documented the sale as an ordinary related-party transaction. Argentina's rule for exports routed through international intermediaries asks a different set of questions. We traced the chain through to the final customer, established what the intermediary did, where its people sat and what risks it actually bore, and documented the pricing on that basis. The engagement produced a file addressing the intermediary rule directly rather than by analogy, with the evidence for each assertion attached to it.

Case study 2

Filing regime rebuilt after a year was prepared late

A subsidiary had treated its transfer pricing analysis as something to be assembled if anyone asked, and discovered that Argentina requires it to be filed. We worked back through the year's related-party transactions, built the analysis to the standard a submitted study needs rather than a held one, and brought the prescribed reporting into order. The work produced the filed study and reporting for the year in question, and a working timetable that starts the analysis early enough in the following year for it to be prepared properly.

Case study 3

Correspondence reconciled across the change of revenue agency

A group held guidance, resolutions and correspondence issued under two different agency names and was unsure which of it still applied. The former agency had been dissolved and its legal successor created in its place, while the underlying obligations continued unchanged. We went through the file, separated what had actually changed in substance from what had only changed in name, and restated the current position. The engagement produced a consolidated reference for the group's Argentine obligations, each item tied to the source it came from and the date that source was read.

Case study 4

Management fee from the parent supported for an Argentine subsidiary

A local subsidiary was charged an annual fee by its parent with little behind it beyond an intercompany invoice. In a jurisdiction where the study is filed, that is visible immediately. We established what the parent actually performed for the subsidiary, who did it and where, how the cost base was built and how it was allocated, and matched a method to those facts. The work produced a documented charge with its supporting evidence attached, and a monthly record that keeps the benefit test current rather than reconstructed at the year end.

Case study 5

Customs values and documented prices brought into line

A group declared one value for goods entering Argentina and documented another as its arm's-length price, without anyone having compared the two. The tax administration and the customs administration sit inside the same agency. We mapped the flows, identified where the two figures diverged and why, and set out which of the differences were genuine and which were an artefact of how each set of paperwork had been prepared. The engagement produced a reconciled position across both sets of filings and a procedure to keep them aligned going forward.

Case study 6

First-year documentation built for a new Argentine subsidiary

A group established a subsidiary in Argentina and had no local analysis for its first year of related-party dealings. We identified the transactions, established which entity performed which functions and carried which risks, selected a method on those facts and justified the selection, then built the study to the standard the filing regime requires. The engagement produced a complete first-year study and the prescribed reporting, plus a description of each flow consistent with how the group documents the same arrangements elsewhere.

Case study 7

Documentation Built to the US Standard

The US requirements differ from the OECD-aligned ones in what has to exist at the time of filing, and a file prepared for one regime can leave the other unprotected. The engagement builds to whichever governs.

Read how this one runs
Case study 8

Indian Transfer Pricing Certification With a Hard Deadline

An Indian entity with international related-party transactions needs an accountant's report filed by a date of its own, ahead of the return. The work is reconciling the transactions to the books first, because the report is only as defensible as that reconciliation.

Read how this one runs

All case studies — every published engagement in one place.

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