Argentina Lifts International-Reporting Bar to $500 Million as ARCA Eases Corporate Tax Prepayments

Decree 767/2025, published Oct. 28, raises the annual threshold to $500 million for import and export operations that must be reported to ARCA and allows the agency to increase it based on price trends. The decree updates transfer‑pricing triggers, requiring special sworn statements from $150 million in aggregate operations or $15 million per individual transaction. It refines the definition of quoted goods and mandates electronic registration of export contracts within 60 days of shipment, warning that unreported operations will not be treated as registered for tax purposes. ARCA’s Resolution 5778/2025 lets companies request income‑tax advance reductions from the third installment if projected payments exceed the estimated liability by more than 25% or from the first if the gap is over 40%, with individuals’ rules unchanged. Special‑review floors rise to $250 million for Segment 11 taxpayers and $200 million for others with CPI indexation from March 2027, a 60‑day review window, and a silence‑positive rule, while ARCA also applies a 15.10% update to deductions and scales from November and opens the simplified return regime to certain foreign‑source income in defined cases.