ARCA has updated Argentina’s International Transactions and Transfer Pricing (TP) regime through General Resolution (GR) 5903/2026, which replaces General Resolutions 4717 and 5010 and their amendments. In addition to raising filing thresholds, the GR introduces simplification options and further guidance on the economic analysis and documentation of international transactions within its scope.   The GR entered into force on 30 September 2026 and applies to fiscal years beginning on or after 1 October 2026. For companies whose fiscal year ends on 31 December, the first fiscal year covered will be 2027.

Ecuador’s Internal Revenue Service (SRI) issued a circular in March explicitly clarifying that the country has not incorporated the simplified Transfer Pricing (TP) approach proposed by the Organization for Economic Co-operation and Development (OECD), known as “Pillar One – Amount B”. This mechanism, designed to streamline the application of the arm’s length principle to basic marketing and distribution activities, was published by the OECD in February 2024 as a voluntary adoption option for jurisdictions.

Following the update of the thresholds applicable to the Information Regime for International Transactions and Transfer Pricing (TP), Form F.2668 has gained renewed relevance for taxpayers subject to the regime. In particular, the questionnaire included in Form F.2668 (the annual – return filed by taxpayers subject to the regime) has been expanded and reoriented towards a fiscal risk management approach, which means that, in practice, it may operate as a risk profiling tool for ARCA.

The landscape has changed, and that is already becoming apparent in practice. With the update to the sanctions regime applicable as of 2026, penalties for formal non-compliance in the area of International Operations have taken on significantly greater weight. And this doesn’t only affect large Multinational Groups: it can also impact importing or exporting companies, even when they operate with independent parties.