On 30 September 2026, ARCA published General Resolution 5903/2026, consolidating Argentina’s transfer pricing rules into one text and repealing five earlier resolutions.
The rules apply to fiscal years starting on or after 1 October 2026, raise Local File, Form F.2668 and Master File thresholds, and set new filing deadlines.
New technical rules include a 5% markup safe harbour for low-value services, substance requirements for foreign intermediaries, and downward adjustments only through MAP.
Note: the source says the thresholds are in Argentine pesos but labels them “USD” in its table (e.g. 3 billion for the Local File). That looks like a source error, so I kept the figures out; worth checking the Official Gazette if you want to cite them.