Decree 767/2025, issued on 28 October 2025, amends the Income Tax Law Regulatory Decree, effective for fiscal years ending on or after 29 October 2025.

With respect to transfer pricing provisions, this decree updates the annual minimum thresholds applicable to transfer pricing returns and introduces certain corrections and relaxations to the existing regulations.

The main changes introduced by the decree are detailed below.

Materiality thresholds

Thresholds that must be met for transactions to comply with the obligation to file annual transfer pricing returns are amended as follows:

• For transactions with independent parties not located in low-tax or no-tax jurisdictions (LNTJs) or noncooperative jurisdictions, the minimum threshold is increased to an amount equivalent to 500,000,000 Argentinian pesos (ARS 500m).
• For transactions with related parties and/or parties located in LNTJs or noncooperative jurisdictions, the minimum threshold is increased to an annual transaction total equivalent to ARS150m or ARS15m per individual transaction.

In both cases, the tax authority (Revenue and Customs Control Agency — ARCA) is empowered to increase the respective amounts.

Export transactions of quoted goods

Certain adjustments are introduced to the contract registration regime applicable to export transactions involving commodities.

The main amendment authorizes ARCA to define the maximum registration period, which shall not exceed 60 days from the shipment date. Furthermore, this period may vary depending on the applicable commercial terms and will be subject to regulations issued by ARCA.

Implications

Affected entities should review their compliance processes in light of these changes, particularly regarding transfer pricing documentation and export contract registrations, to ensure adherence to the updated regulations.