Transfer Pricing

We advise national and international companies on compliance with their transfer pricing obligations, ensuring that transactions between related parties are carried out in accordance with the market value principle.

Our approach not only responds to the legal requirements in Mexico, but also offers a strategic and sectorial vision for better financial and tax planning, aligned with global best practices and OECD guidelines.

Technical analysis with strategic vision and regulatory compliance

The transfer pricing service is based on the detailed analysis of transactions between related companies -such as financing, services, licenses, manufacturing, distribution or purchase and sale of assets- in order to validate that the prices, margins or considerations are consistent with those that would have been agreed upon by independent parties under comparable conditions.

This analysis allows our clients to avoid tax adjustments, legal contingencies or fines, and at the same time offers them a tool to review the economic efficiency of their international or corporate operation.

What is a related party?

A related party is considered when a person or group participates directly or indirectly in the management, control or capital of another company. Common examples include:

Companies controlled by the same shareholders
Parent company and its subsidiaries
Entities with common administration
Family members with an interest in the capital or management of a company
Companies controlled by the same economic group

How do we help our customers?

Preparation of the Transfer Pricing Study In accordance with Articles 179 and 180 of the Income Tax Law and the OECD Transfer Pricing Guidelines.
Presentation of Annex 9 of the Multiple Informative Declaration (DIM).
Preparation of BEPS information returnsLocal, Master and Country-by-Country Statement.
Benchmarking of intercompany operationsincluding: Services, Financing, Use of intangible assets, Real estate leasing, Manufacturing, distribution and marketing.
Safe Harbor applicationwhen applicable.
Interactive display of resultsto facilitate decision making by management.
Support in filling out transfer pricing information in: Information on Tax Situation (ISSIF) and Tax Report.

Coverage and sectors served

We work with business groups, multinational companies and family businesses with complex structures, in sectors such as: Manufacturing and Export, Technology and Software, Logistics and Distribution, Financial and Professional Services, Energy, Pharmaceuticals and Food.