Argentina Transfer Pricing

General reference only. This skill is general tax/accounting reference material for AI-assisted workflows. It has not been reviewed for any specific person's facts, documents, elections, deadlines, residency, filing status, or local procedures. Do not rely on it to file, pay, amend, or take a tax position without review by a qualified professional in the relevant jurisdiction.

Who this applies to

Argentine business taxpayers within LIG art. 53(a)-(d), including relevant permanent establishments, with foreign related-party transactions, transactions involving non-cooperative or low/no-tax jurisdictions, or imports/exports of goods between independent parties. Related and low-tax/non-cooperative transactions are subject to TP analysis; unrelated goods trade has its own information/documentation obligations. RG 5903 art. 2 expressly excludes persons importing/exporting for the account and order of the goods owner; the owner reports those goods. Scope sources: RG 4717 arts. 1-3; RG 5903 arts. 1-3.

Quick answer: get the fiscal year's start and end dates first. Calendar-year 2026 started before the new regime and remains under RG 4717, as amended by RG 5798. RG 5903, published on 30 September 2026, applies to years starting from 1 October 2026. Its higher thresholds must not be used to dispense with a calendar-2026 local file. Below a reporting threshold does not mean prices are exempt from the arm's length rule.

This is a Tier 2 source-cited draft without accountant approval. It produces a transaction inventory, method/threshold memo and reporting checklist. It does not choose comparables without evidence. Corporate tax itself belongs to ar-corporate-income-tax; source and withholding belong to argentina-cross-border.

Relatedness is determined under LIG art. 18 and Decreto 862 art. 14, including management, capital/control and economic influence, not only a shareholding percentage. RG 5903 art. 3 clarifies that a sole/principal customer or supplier relationship is caught where losing it, even temporarily, would paralyse either party's activity. For old-regime years, RG 4717 art. 3 uses the broader absence-might-affect-continuity-or-existence test; do not apply the new paralysis wording to exclude a calendar-2026 counterparty. Use contracts, control charts and actual conduct to apply the test.

Out of scope: commodity export contract registration under the separate regime, industry-specific quoted-price valuation, unique intangibles/business restructuring valuation, APAs and litigation. Identify these facts and refer them, retaining their transactions in the reporting inventory. The ordinary documentation and method rules below still apply where relevant.

Rates, bands and thresholds

All peso thresholds below concern reporting and documentation, not a tax rate or permission to depart from market terms. "Exceeds" means strictly greater, not greater than or equal.

Fiscal years beginning before 1 October 2026

For fiscal years closing from 31 October 2025 and beginning before the new regime, use RG 4717 as amended by RG 5798. This includes calendar-year 2026.

Obligation	Trigger, ARS unless stated	Conditions and official source
F.2668, independent goods trade	Annual imports + exports exceed 500,000,000	RG 4717 art. 48(a), including exempt/non-taxable activities; https://biblioteca.arca.gob.ar/dcp/REAG01004717_2020_05_14
F.2668, TP transactions	Aggregate exceeds 150,000,000 or individual transaction exceeds 15,000,000	Art. 48(b), related/low-tax/non-cooperative scope; https://biblioteca.arca.gob.ar/dcp/REAG01004717_2020_05_14
Local TP study	Aggregate exceeds 150,000,000 or individual transaction exceeds 15,000,000	Art. 44(a)-(b), invoicing attributable to the accrual period; https://biblioteca.arca.gob.ar/dcp/REAG01004717_2020_05_14
Master file	Prior-year group consolidated revenue exceeds 100,000,000,000 AND current foreign-related transactions exceed 150,000,000 aggregate or 15,000,000 individually	Art. 45, both group and transaction tests; https://biblioteca.arca.gob.ar/dcp/REAG01004717_2020_05_14
No-movement F.2668	A filing with movements in either of the previous two fiscal years	Art. 47; after two consecutive no-movement filings, further filings cease until retriggered; https://biblioteca.arca.gob.ar/dcp/REAG01004717_2020_05_14

Fiscal years beginning on or after 1 October 2026

Obligation	Trigger, ARS unless stated	Conditions and official source
F.2668, independent goods trade	Aggregate imports + exports exceed 7,500,000,000	RG 5903 art. 58(a), including exempt/non-taxable activities; https://biblioteca.arca.gob.ar/search/query/norma.aspx?p=t%3ARAG%7Cn%3A5903%7Co%3A9%7Ca%3A2026%7Cf%3A28%2F09%2F2026
F.2668, TP transactions	Aggregate exceeds 1,500,000,000 or individually exceeds 300,000,000	Art. 58(b); when either information trigger applies, report all international transactions of both categories; https://biblioteca.arca.gob.ar/search/query/norma.aspx?p=t%3ARAG%7Cn%3A5903%7Co%3A9%7Ca%3A2026%7Cf%3A28%2F09%2F2026
Local TP study, ordinary threshold	Aggregate exceeds 3,000,000,000 or individually exceeds 600,000,000	Art. 60(a); include accrued interest without invoices and estimated market value of unremunerated dealings; https://biblioteca.arca.gob.ar/search/query/norma.aspx?p=t%3ARAG%7Cn%3A5903%7Co%3A9%7Ca%3A2026%7Cf%3A28%2F09%2F2026
Local TP study, CbCR group	F.2668 obligation under art. 58(b) AND membership of a group required to file CbCR	Art. 60(b); the ordinary local-study threshold is not the only trigger; https://biblioteca.arca.gob.ar/search/query/norma.aspx?p=t%3ARAG%7Cn%3A5903%7Co%3A9%7Ca%3A2026%7Cf%3A28%2F09%2F2026
Master file	Prior-year group consolidated revenue exceeds 500,000,000,000 AND foreign-related transactions exceed 3,000,000,000 aggregate or 600,000,000 individually	Art. 63; group revenue translated at parent's closing exchange rate; https://biblioteca.arca.gob.ar/search/query/norma.aspx?p=t%3ARAG%7Cn%3A5903%7Co%3A9%7Ca%3A2026%7Cf%3A28%2F09%2F2026
Certain intermediary information relief	Total intermediary transactions below 15,000,000,000	Art. 57 relieves only art. 55(b) information, not every intermediary record; https://biblioteca.arca.gob.ar/search/query/norma.aspx?p=t%3ARAG%7Cn%3A5903%7Co%3A9%7Ca%3A2026%7Cf%3A28%2F09%2F2026
Independent-trade simplified route	More than 7,500,000,000 but less than 45,000,000,000	Art. 64(3), subject to art. 65 exclusions; https://biblioteca.arca.gob.ar/search/query/norma.aspx?p=t%3ARAG%7Cn%3A5903%7Co%3A9%7Ca%3A2026%7Cf%3A28%2F09%2F2026
No-movement F.2668	Filing with movements in either previous two fiscal years	Art. 58; two consecutive no-movement filings end carry-on obligation until retriggered; https://biblioteca.arca.gob.ar/search/query/norma.aspx?p=t%3ARAG%7Cn%3A5903%7Co%3A9%7Ca%3A2026%7Cf%3A28%2F09%2F2026
First indexation	Years beginning 1 January 2028 onward	Art. 75: October 2027/October 2026 IPC, rather than a first increase in 2027; https://biblioteca.arca.gob.ar/search/query/norma.aspx?p=t%3ARAG%7Cn%3A5903%7Co%3A9%7Ca%3A2026%7Cf%3A28%2F09%2F2026

An entity with an exemption certificate under the specified LIG art. 26(b),(d),(e),(f),(g),(l),(p) provisions is excluded from submitting the study by RG 5903 art. 60. This is a study-submission exception, not a blanket statement that every international reporting duty disappears.

Country-by-country reporting: separate test

Item	Threshold or deadline	Conditions and official source
CbCR group exclusion	Prior-year consolidated revenue below EUR 750,000,000, or equivalent in parent jurisdiction currency using January 2015 exchange rate	RG 4130 art. 2; prorate for an irregular prior fiscal year; https://biblioteca.arca.gob.ar/dcp/REAG01004130_2017_09_19
Report deadline	Last business day of the twelfth month following the parent year-end	RG 4130 art. 7; https://biblioteca.arca.gob.ar/dcp/REAG01004130_2017_09_19
Local constituent notification	Last business day of third month after parent year-end	Art. 8, notification does not itself mean the entity files CbCR; https://biblioteca.arca.gob.ar/dcp/REAG01004130_2017_09_19
Confirmation of overseas report	Last business day of second month after report due date	Art. 8, in addition to initial notification; https://biblioteca.arca.gob.ar/dcp/REAG01004130_2017_09_19

The base

Transaction inventory and method

Use LIG arts. 9, 16-20, 126-127 and Decreto 862 arts. 14, 28-42.

1. Inventory the business's international transactions by counterparty, country, relationship, contract, amount, currency, accrual period and tax treatment. Test low/no-tax and non-cooperative status independently; absence of common ownership does not remove that route into TP.
2. Delineate the actual transaction: functions, assets, economically significant risks, contractual terms, conduct, market and business strategy. Reconcile the transaction total to the accounts, customs and income-tax working papers. Identify services rendered without an invoice or consideration.
3. Select and document the most appropriate method under Decreto 862 arts. 29-30: comparable uncontrolled price, resale price, cost plus, profit split, transaction net margin, or refer the limited other-method cases in art. 29(f): unique/valuable intangibles, unquoted financial assets and unique investments, where standard methods are inappropriate and the documented alternative is superior. Lack of a convenient comparable does not itself authorise another method. Do not choose a method merely because a database is convenient.
4. Use reliable comparable uncontrolled transactions and justified consistent adjustments. Document the search universe, acceptance/rejection criteria, sources and dates. Segment accounts where the transaction/business line requires it. Cost-plus tests gross profit relative to the relevant costs; TNMM tests an appropriate net indicator. Do not interchange the two margins.
5. Apply the range/adjustment rule, then map the adjustment into the corporate income-tax reconciliation and international forms. Do not claim an unsupported downward adjustment: RG 4717 art. 37 and RG 5903 art. 49 prohibit using TP to invent deductions, reduce agreed sale/income consideration or increase agreed purchase/expense consideration.

For years within RG 5903, arts. 4-8 require assessment of unremunerated dealings and accounting transactions that can affect tax in another year; exclude an item only with evidence that it can never affect the tax. Local tested party is the starting rule. Old RG 4717 art. 5 requires local analysis, with all profit-split parties considered; art. 42 requires the last three closed commercial years of consolidated audited/certified accounts when analysing the foreign profit-split party. Under new RG 5903, a less complex foreign tested party is permitted only with resale-price, cost-plus or TNMM, for received services excluding art. 19 financing, LIG art. 17 sixth-paragraph international-intermediary goods dealings, imports below 2% of total operating costs, or exports below 2% of total sales. All art. 6 conditions are concurrent: reliable sufficient reconciled information, fewer adjustments, no valuable/unique intangibles for that foreign party. Profit split analyses every involved related party. Art. 54 requires the foreign tested party's used-period accounting information to be independently accountant/auditor/equivalent certified in origin, and certified Spanish translation on request. A foreign party cannot be selected merely because its result is more favourable.

Range, median and tax adjustment

Decreto 862 art. 42, as amended by Decreto 767/2025, treats a result inside the interquartile range as arm's length; otherwise use the median. Where there are two or more comparable transactions, determine the median and interquartile range under Decreto 862 art. 42. Compute the order statistics under RG 4717 art. 29 or RG 5903 art. 39, not a software default:

• Sort the comparable values ascending; retain repeated values as separate observations.
• Median position = (number of observations + 1) / 2.
• First-quartile position = (median position + 1) / 2.
• Third-quartile position = median position - 1 + first-quartile position.
• Where a position is fractional, interpolate between the adjacent ordered values.

Quoted goods/services have a different art. 42 rule: the day's minimum/maximum quoted-price range, with a result outside it adjusted to their average, subject to the regulation's adjustments and timing controls. Do not apply the ordinary interquartile example to a commodity export.

Documentation and simplified route

The local study must substantiate the transactions and mathematical methods with underlying records. RG 4717 art. 43 and RG 5903 art. 61 require independent accounting/economics professional certification authenticated by the professional body. Under RG 5903, include the extra financing information in Annex I B where cross-border group financing exists. Retain working papers at the taxpayer's fiscal domicile under RG 5903 art. 71.

Master-file reporting is separate from the study. Under RG 4717 art. 45 and RG 5903 art. 63, an unchanged master file can be replaced by a signed ratification note plus the specified financial information only if the immediately prior year's master file or ratification was filed. One local group entity may report, but the other local entities still submit F.2673 as reported entities identifying the reporter. Under RG 5903, a master file can be in Spanish or English, with a certified Spanish translation supplied on request.

The simplified route does not waive market pricing. For the royalty/licence/R&D and service caps in both regimes, covered means dealings with related counterparties and/or counterparties domiciled, constituted or located in non-cooperative or low/no-tax jurisdictions. For old-regime years, RG 5010 governs F.2672; do not import RG 5903's money thresholds into those years. The operative old routes and filing flow are set out below. For new-regime years, RG 5903 arts. 64-69 permit F.2672 instead of F.2668 and the study if one complete route applies:

Route	All material conditions	Official source
Small business	Annual turnover below the largest medium-company tranche 1 amount; no losses in the financial statements or restructuring in the current and two prior years; covered royalties/licences/R&D no more than 1% of that tranche amount; covered services no more than 1% of local turnover; no foreign-related borrowing/lending	RG 5903 art. 64(1); https://biblioteca.arca.gob.ar/search/query/norma.aspx?p=t%3ARAG%7Cn%3A5903%7Co%3A9%7Ca%3A2026%7Cf%3A28%2F09%2F2026
Low related-party intensity	Total foreign-related transactions no more than 2.50% of turnover; covered royalties/licences/R&D no more than 0.50% of turnover; no losses in the financial statements or restructuring in current and two prior years; no specified international intermediary in goods trade	Art. 64(2); https://biblioteca.arca.gob.ar/search/query/norma.aspx?p=t%3ARAG%7Cn%3A5903%7Co%3A9%7Ca%3A2026%7Cf%3A28%2F09%2F2026
Independent goods trade	Within the lower/upper bounds in the table above	Art. 64(3); https://biblioteca.arca.gob.ar/search/query/norma.aspx?p=t%3ARAG%7Cn%3A5903%7Co%3A9%7Ca%3A2026%7Cf%3A28%2F09%2F2026
Exclusion from every route	Membership of a group obliged to file CbCR anywhere OR obligation to file a master file/ratification	Art. 65; https://biblioteca.arca.gob.ar/search/query/norma.aspx?p=t%3ARAG%7Cn%3A5903%7Co%3A9%7Ca%3A2026%7Cf%3A28%2F09%2F2026

The current largest medium-tranche-1 ceiling from 1 April 2026 is ARS 64,238,670,000 (industry/mining), so 1% is ARS 642,386,700, under SICyPyME Resolution 1/2026 Annex I table A: https://biblioteca.arca.gob.ar/search/query/adjunto.aspx?p=t%3ARES%7Cn%3A1%7Co%3A62%7Ca%3A2026%7Cd%3Aanexo_7611797_1.pdf . Use the applicable older ceiling for earlier periods; do not backdate the April value. F.2672 includes a declaration of eligibility, market pricing and no international intermediary under art. 66. Under RG 5903 art. 69, ARCA may demand the study and working papers within 45 days of notice where market conditions, risk or other stated strategies justify it and covered transactions exceed ARS 3,000,000,000 in total or ARS 600,000,000 individually. Do not elect without a documented test of every condition.

Calendar-2026 simplified election under RG 5010

RG 5010 arts. 1-8, current text provides these alternative routes, subject to the CbCR-anywhere and master-file exclusions in art. 2:

• Small-business route: turnover below the applicable largest medium-tranche-1 ceiling; no recurrent financial-statement losses or restructuring in the current/two prior years; covered royalties/licences/R&D no more than 1% of that ceiling; covered services no more than 1% of turnover; no foreign-related borrowing/lending. The old financial-statement test says recurrent losses, unlike the new absolute no-loss test.
• Low-intensity route: foreign-related dealings no more than 2.50% of turnover; covered royalties/licences/R&D no more than 0.50% of turnover; no recurrent losses or restructuring in current/two prior years; no specified international goods intermediary.
• Exempt-entity route: entities under LIG art. 26(b),(d),(e),(f),(g),(l),(p), with RG 2681 exemption certificate. This old simplified route is distinct from the new art. 60 study exemption.
• Independent goods-trade route: total strictly above ARS 500,000,000 and strictly below ARS 3,000,000,000 for periods closing from 31 October 2025 under RG 5798.

F.2672 includes sworn eligibility, independent-party pricing and no international intermediary. Submit through Presentación de DDJJ y Pagos, Clave Fiscal level 3 or above, by sixth-month CUIT days 23/24/25/26/27 with the consecutive business-day roll. A valid election replaces F.2668 and the study. ARCA can still demand the study and working papers within 45 days after notification on the stated risk/market/strategy grounds if total dealings exceed ARS 150 million or an individual dealing exceeds ARS 15 million (art. 7).

Ordinary service, financing and comparable controls

Use RG 4717 arts. 6, 11-16 and RG 5903 arts. 8, 14, 16-25, 45-49:

• Normally exclude operating-loss comparables unless detailed objective evidence shows their losses do not impair comparability. Under RG 5903, multiyear recurring losses means losses in a majority of analysed periods or a negative simple average; insolvency/bankruptcy during any analysed year is also excluded absent the stated justification.
• Net-margin operating analysis excludes financial results, extraordinary items, capital gains/losses and income tax. Under RG 5903, do not remove normal/routine local taxes or costs as adjustments without demonstrating improved reliability.
• Services need actual benefit/necessity evidence. Do not charge unnecessary, shareholder, acquisition/investor-relations or duplicate services as if all group costs benefited the local company.
• Financing evidence must show lender economic capacity and control of risk, and borrower repayment/guarantee capacity. Passive group membership alone earns no guarantee fee. Document any implicit-support credit-rating analysis and any cash-pool necessity/excess-cash origin.
• RG 5903 art. 48 expressly prohibits downward TP adjustments in the return, except adjustments deriving from treaty mutual-agreement procedures. Art. 49's separate deduction safeguards still apply.
• Special residual profit split under Decreto 862 art. 29(d) requires advance notice in the fifth month after closing: RG 5903 art. 45 uses Presentaciones Digitales, Precios de transferencia - Aplicación método de división de ganancias; old RG 4717 art. 33 uses its specified Presentaciones Digitales procedure. Do not wait for the study deadline.

New-regime low-value services option: RG 5903 arts. 16-18 permits functional analysis without a separate comparability analysis if every condition holds. A local service provider's total-operating-cost markup must be at least 5%; a foreign related service provider's markup at most 5%. Received low-value services cannot exceed 10% of local operating expenses; provided low-value services cannot exceed 10% of local operating income. If local is tested, no operating loss or ongoing restructuring. Services must support the recipient, be outside the group's economically significant core activity, neither use nor create unique/valuable intangibles, and neither involve nor create significant provider risk. Art. 16 benefit/exclusion tests still apply. This is a directional conditional option, not a universal fixed 5% safe harbour, and does not apply to calendar-2026 old-regime years.

Scope classifier and records: LIG art. 20 defines low/no-tax by maximum business-income taxation below 60% of the minimum art. 73 corporate rate: 60% × 25% = 15%, with all-government tax and special-regime analysis under Decreto 862 art. 25. This differs from LIG art. 19 non-cooperation: check the current art. 24 country list and legal exchange criteria. Independent-goods records under RG 4717 art. 38 / RG 5903 art. 51 include counterparty NIF/residence, contracts/pricing/payment/guarantees, banking/SWIFT documents and international-price sources. Retain these even when reporting relief applies.

Deadlines and filing

Old-regime years: RG 4717 art. 51 sets the study and F.2668 deadline in the sixth month following closing, on days 23/24/25/26/27 for CUIT endings 0-1/2-3/4-5/6-7/8-9. The master file is due on the same CUIT days in the twelfth month. Apply the law's holiday/business-day roll-forward, and check exceptional extensions for the period.

For RG 4717 years use Operaciones Internacionales y Precios de Transferencia for F.2668 (art. 48); F.4501 with the certified study and three digital signatures through Presentación de DDJJ y Pagos (art. 46); and F.2673 for master/ratification through that same filing service (art. 45). Foreign-language study and master-file documents require attached Spanish national public-translator translations with translator signature certification (arts. 45-46). Old art. 43 also requires Annex I B group financing information.

New-regime years: RG 5903 art. 70 changes study/F.2668/F.2672 to the seventh month after closing, on days 2/3/4/5/6 for those same CUIT pairs. Master-file/ratification days remain 23/24/25/26/27 in the twelfth month. If a date is non-business, it and subsequent dates move consecutively to the following business days.

For RG 5903:

1. Enter Operaciones Internacionales with Clave Fiscal level 3 or above. F.2668 art. 59 requires the most specific available transaction category/subcategory and the Annex V international tax risk questions for related/low-tax/non-cooperative dealings. Reconcile totals before submitting.
2. Submit certified study and attachments with F.4501 through Presentación de DDJJ y Pagos, following Annex II. The taxpayer, professional and professional-body representative digitally sign. Foreign-language study information requires national public-translator Spanish translation (art. 62).
3. Submit master file or ratification through the same filing service with F.2673, selecting reporter/reported-entity status and identifying the group/reporting entity (art. 63).
4. For an eligible simplified election, submit F.2672 through Presentación de DDJJ y Pagos, with level 3 Clave Fiscal (arts. 66-67). Keep eligibility evidence; do not also treat its substitution as a waiver of master file or CbCR.
5. Retain submission acknowledgement, legalisations, signed attachments and any rejection notices. A prepared upload alone is not evidence of acceptance.

CbCR is under RG 4130 arts. 3 and 6-9. The Argentine ultimate parent reports. A local surrogate must be parent-designated and have at least ARS 50 million net assets or sufficient operational/functional structure (art. 3(b)). A local constituent has secondary filing only for art. 3(c) cases: no parent-country reporting obligation; international agreement with Argentina but no qualifying competent-authority agreement at report due date; or systematic exchange failure. Art. 4 removes secondary filing if a foreign surrogate files under a compliant regime, its jurisdiction has the qualifying agreement at due date and no reported/verified systematic failure, it was notified of the surrogate appointment, and the Argentine entity supplied art. 8(b) reporter information. Test all conditions before imposing a local report. File F.8097 through Presentación de DDJJ y Pagos or the specified web service and check the final acceptance through Domicilio Fiscal Electrónico. Correct rejected data and resubmit. Local notifications use Régimen de Información País por País, Empadronamiento, producing F.8096. Art. 8 local notifications can apply even below the EUR 750 million report threshold. Retain CbCR supporting material until five years after limitation expires for the reported period (art. 13). Do not confuse notification, master file and the CbCR report.

Penalties and interest

RG 5903 art. 72 refers non-compliance to Ley 11.683 and notes increased SIPER audit-risk classification. RG 4130 art. 12 treats CbCR default as a significant risk indicator. A missed information return and an income-tax shortfall are different exposures; quantify them separately. Current 2026 fine amounts and interest rates were not confirmed here and must not be inferred from the pre-2026 nominal amounts. The reporting threshold is not a penalty-free tolerance.

Cross-border points

LIG source and deductibility requirements remain separate from TP, including foreign-related interest, royalties, treaty relief and withholding. A benchmark does not prove that a service happened, benefited the recipient, or is deductible. Keep service evidence, contracts, benefit tests and payment/withholding evidence. A foreign adjustment is not automatically an Argentine corresponding adjustment; treaty mutual-agreement procedures need case-specific review. Do not substitute a CbCR allocation for a transactional arm's length analysis (RG 4130 art. 14(b)). Use argentina-cross-border for the initial withholding/residence analysis.

Two worked examples that recompute

1. Cost-plus pricing and an upward income adjustment

Assume a properly selected cost-plus method for an Argentine related-party service provider, comparable gross markup 8%, relevant cost base ARS 100,000,000 and invoiced service revenue ARS 105,000,000. Arm's length revenue is 108,000,000, implying an upward income adjustment of 3,000,000. The 8% is a hypothetical benchmark, not a statutory safe harbour. Deductibility, service evidence and the real comparable set still need review. Method: Decreto 862 art. 29(c); no invented downward deductions: RG 4717 art. 37 / RG 5903 art. 49.

name: Cost-plus service price
inputs:
  relevant_cost: 100000000
  comparable_gross_markup: 0.08
  invoiced_revenue: 105000000
steps:
  - market_revenue: relevant_cost * (1 + comparable_gross_markup)
  - upward_income_adjustment: max(0, market_revenue - invoiced_revenue)
expected:
  market_revenue: 108000000
  upward_income_adjustment: 3000000

2. Inside the range or adjusted to the median?

Assume five valid comparable net margins, sorted 2%, 4%, 6%, 8%, 10%, ordinary unquoted service transactions and the same denominator. Median position 3 gives 6%; first-quartile position 2 gives 4%; third-quartile position 4 gives 8%. On ARS 200,000,000 sales, a tested 5% margin gives 10,000,000 profit and is inside the range: no TP margin adjustment. A tested 3% margin gives 6,000,000 and is below the range: the median result is 12,000,000, with upward adjustment 6,000,000. Do not adjust merely to the 4% lower quartile. Sources: Decreto 862 art. 42 and RG 4717 art. 29 / RG 5903 art. 39.

name: Interquartile range decision
inputs:
  count: 5
  sales: 200000000
  median_margin: 0.06
  inside_margin: 0.05
  outside_margin: 0.03
steps:
  - median_position: (count + 1) / 2
  - first_quartile_position: (median_position + 1) / 2
  - third_quartile_position: median_position - 1 + first_quartile_position
  - inside_profit: sales * inside_margin
  - outside_profit: sales * outside_margin
  - median_profit: sales * median_margin
  - outside_adjustment: median_profit - outside_profit
expected:
  median_position: 3
  first_quartile_position: 2
  third_quartile_position: 4
  inside_profit: 10000000
  outside_profit: 6000000
  median_profit: 12000000
  outside_adjustment: 6000000

Ask the client first

1. Fiscal-year opening/closing dates, CUIT ending, and the current/prior two years' international filings.
2. Group/control structure, counterparty jurisdictions, permanent establishments and low-tax/non-cooperative exposure.
3. Accrued transactions, contracts, invoices, free services/financing, customs values and reconciled segmented accounts.
4. Functions, assets, risks, intangibles, comparable evidence and any business restructuring.
5. Prior-year group consolidated revenue, CbCR reporter/exchange status, master-file history and local reporting entities.
6. Simplified-route facts: turnover, losses, royalties, services, lending/borrowing and intermediaries across the relevant periods.

Sources

All entries identify the parts actually read. The cache of official texts is outside git; exact quotations identify the controlling language.

Source and text read	Official URL	Read on
Read for scope and methods: LIG arts. 9, 16-20, 126-127; quotation: "condiciones se ajusten a las prácticas normales del mercado"	https://biblioteca.arca.gob.ar/dcp/LEY_C_020628_2019_12_05	2026-11-11
Read for methods/ranges: Decreto 862 arts. 14, 29-30, 40-42, including Decreto 767/2025 amendment; quotation: "es el valor de la mediana"	https://biblioteca.arca.gob.ar/dcp/DEC_C_000862_2019_12_06	2026-11-11
Read for pre-transition reporting: RG 4717 current arts. 1-3, 28-51, especially 44, 45, 47, 48, 51; quotations: "CIENTO CINCUENTA MILLONES", "CIEN MIL MILLONES"	https://biblioteca.arca.gob.ar/dcp/REAG01004717_2020_05_14	2026-11-11
Read for new regime: RG 5903 arts. 1-8, 14, 16-25, 39, 45-49, 51-75 and filing provisions; quotations: "TRES MIL MILLONES", "primer día del mes inmediato siguiente", "1° de enero de 2028"	https://biblioteca.arca.gob.ar/search/query/norma.aspx?p=t%3ARAG%7Cn%3A5903%7Co%3A9%7Ca%3A2026%7Cf%3A28%2F09%2F2026	2026-11-11
Read for old simplified election: RG 5010 current arts. 1-8; quotation: "resultados negativos recurrentes"	https://biblioteca.arca.gob.ar/dcp/REAG01005010_2021_06_16	2026-11-11
Read for SME ceiling: Resolution 1/2026 arts. 1, 3 and Annex I A, largest medium-tranche-1 entry; quotation: "64.238.670.000"	https://biblioteca.arca.gob.ar/search/query/adjunto.aspx?p=t%3ARES%7Cn%3A1%7Co%3A62%7Ca%3A2026%7Cd%3Aanexo_7611797_1.pdf	2026-11-11
Read for CbCR: RG 4130 current arts. 2-4, 6-9, 12-14; quotation: "inferiores a SETECIENTOS CINCUENTA MILLONES DE EUROS"	https://biblioteca.arca.gob.ar/dcp/REAG01004130_2017_09_19	2026-11-11

Not yet confirmed: current 2026 fines and interest; period-specific exceptional filing extensions. Commodity contract registration is not computed here; refer before registering. APA and unique intangible valuations are outside this Guide.