On 24 August 2009, a Presidential Decree (new Regulations) was enacted to modify the transfer pricing regulations issued on 26 January 2009 (old Regulations). According to Law 18,083, transactions between a resident taxpayer, and an entity located, incorporated, resident or operating in (i) a tax haven or (ii) a customs enclave (CE) (e.g. a free zone) that enjoys a low-tax regime, are deemed to be performed between related parties. For this presumption to apply, the old Regulations established a comprehensive list of low-tax jurisdictions, but they remained silent with regards to operations performed with entities located, incorporated, resident or operating...