Argentina Transfer Pricing Policy

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.

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.

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.

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.

Three things have changed the shape of transfer pricing work everywhere, and they are all visible in Argentina. Tax administrations now receive structured group data before they open a file, so risk is selected on evidence rather than sampled. Intangibles and intra-group financing have displaced goods pricing as the main source of adjustment. And documentation timing has become a substantive issue in its own right, separate from whether the price was right.

Where challenges concentrate in Argentina

• Inflation and currency movement break comparability within a single year. A margin benchmarked against a set drawn from a different price environment needs an explicit adjustment, and Argentine files that carry a prior-year search forward are carrying forward an assumption.
• The intermediary rule catches commodity structures that were designed for a different purpose. Where an offshore related trader sits between an Argentine exporter and the market, its function has to be substantiated.
• The agency transition from AFIP to ARCA means procedural references in older documentation and older filings point at an authority that no longer exists under that name. Updating the mechanics is trivial; discovering it late is not.

What it costs when the file is not there

The cost of a thin file in Argentina is rarely just the tax. It is the adjustment, the charge or penalty attached to it, the years it stays open, the management time an audit consumes, and the corresponding position in the counterparty jurisdiction that may not be relieved. Priced against that, the documentation is the cheap part.

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.