Transfer pricing

The effects of the ongoing globalization, the increase in the significance and complexity of operations among large multinational groups, the BEPS action plan launched by the OECD and the growing control and supervision of said operations by international tax authorities, among other elements, have given rise to the need for sufficient and reasonable information to ensure that most taxpayers that carry out the operations described above with foreign individuals or companies comply with applicable transfer pricing obligations.

Therefore, and in order to avoid unnecessary double-taxation risks, our Firm provides our clients with transfer pricing services based on reliable research practices and documentary evidence to which reasonable economic approaches have been applied.  The ultimate goal of our transfer pricing practice is supporting our clients by providing them with the documentation they need to demonstrate that the transactions they carry out within their group comply with market requirements, and that these transactions do not minimize the taxable base for income tax in Mexico.

We provide comprehensive consultancy services which are not limited to the annual preparation of supporting documentation. On the contrary, we provide support for the preparation of informative tax returns (DIM A9, local and master files, and CbCR reports), as well as annexes and questionnaires included in audited or unaudited reports for tax purposes (SIPRED, ISSIF).

We provide comprehensive consultancy services which are not limited to the annual preparation of supporting documentation. On the contrary, we provide support for the preparation of informative tax returns (DIM A9, local and master files, and CbCR reports), as well as annexes and questionnaires included in audited or unaudited reports for tax purposes (SIPRED, ISSIF).

In case our clients require specialized transfer pricing services, we assist them in examination processes performed by audit teams, assistance and support in mutual agreement procedures, assistance in processing and obtaining advance pricing agremeents, as well as assistance and support in mediation processes performed at the Mexican Taxpayers’ Ombusdman office.