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Project of Replacement of the General Resolution on Transfer Pricing

On November 20, 2025, as part of a novel public consultation procedure, the Customs Revenue and Control Agency (ARCA) has made available a draft replacement for General Resolution No. 4717/2020—its amendments and supplements—and General Resolution No. 5010/2021, on the transfer pricing regime provided for in the income tax law.


This publication was prepared on November 20, 2025, and does not constitute legal advice. For more information, please contact:

Tax Law Area

Celina Valls vallsM@eof.com.ar

Jalhil Damus Pastorio pastorioj@eof.com.ar