Argentina Consulting on New General Resolution on Transfer Pricing and International Operations

On 9 December 2025, the Argentine Tax Authority (ARCA) issued a release on a draft general resolution for the replacement of General Resolution 4717/2020 of 14 May 2020, which is currently under consultation. General Resolution 4717/2020 regulated Argentina's new rules on transfer pricing and international operations introduced by Law 27,430 of 2017 (2018 tax reform law) and implemented by Decree 1170 of 2018. Some of the key changes include an increase in transfer pricing documentation an…