The Revenue and Customs Control Agency (ARCA) establishes parameters for virtual wallets and payment service providers to report certain transactions of their users. The threshold of $2,500,000 per transaction may raise questions, but it does not represent a limit for transferring money nor does it automatically trigger an audit.
General Resolution 5804/2025 sets criteria for determining when it is necessary to report information to the agency. The scheme includes amounts per transaction and monthly thresholds, although it is important to distinguish which conditions must be met and which transactions are covered.
The scheme includes amounts per operation and monthly thresholds
What are the monthly amounts considered by ARCA
The regime establishes different references depending on the type of taxpayer. The monthly thresholds reported for income, expenses, or final balances are:
Individuals: $50,000,000 monthly.
Legal entities: $30,000,000 monthly.
The parameter of $2,500,000 for individual transactions must be analyzed along with the other criteria set forth by the regulation. Therefore, receiving a transfer above that amount does not, by itself, mean that the entity must report it under this regime.
For example, an individual may receive a transfer of $3,000,000 and maintain monthly transactions below the reported thresholds. In that case, the amount of that isolated transaction is not sufficient to determine a reporting obligation.
What are the monthly amounts covered by ARCA
What happens if you transfer more than $2,500,000
Exceeding that amount does not imply that the transfer is prohibited nor that ARCA will automatically initiate an inspection. The parameters serve as informational criteria for the entities covered by the regulation.
The obligation to evaluate the transactions falls on virtual wallets, payment service providers, and providers of account management and intermediation services. These companies must verify whether the transactions of each user meet the conditions established by the regime.
What happens if you transfer more than $2,500,000
The analysis considers the monthly volume and not just a specific transaction. However, exceeding the thresholds does not, by itself, equate to a violation or penalty.
How QR payments and transfers between own accounts are considered
Payments made via QR codes have a particular treatment: the individual threshold of $2,500,000 mentioned for transfers does not apply to them. These transactions may be included in the report if they exceed the corresponding monthly parameters.
Transfers between own accounts are also covered under the informational regime. Transactions between a bank account and a virtual wallet, or between wallets of the same holder, are added to the monthly calculation indicated in the regulation.
How are QR payments and transfers between own accounts considered
Who must report transactions to ARCA
The responsibility to comply with the informational regime lies with the affected companies, not the user. Digital banks, virtual wallets, and payment service providers must evaluate the transactions and submit the information when appropriate.
Users do not have to carry out a specific procedure simply because they exceed a threshold. Nevertheless, it is advisable to keep documentation that allows for the identification of the origin and destination of the funds, especially when dealing with large amounts.
