Part of a comparative survey dealing with the particular constraints and opportunities connected with the relationship between transfer pricing policy and tax and business planning from both a domestic and a treaty law perspective. Although Argentine tax law does not provide specific transfer pricing rules for the treatment of transactions with residents of low-tax countries, it has adopted controlled foreign company (CFC) rules that have an impact on transactions with such non-residents. This article considers the general transfer pricing rules and CFC rules that apply in this context.