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The importance and current needs of transfer pricing studies
March 25, 2025
Ana Gabriela Vázquez
In Mexico, as in many other countries, all companies that conduct transactions with related parties are required to use market-valued consideration to comply with the arm's length principle. However, not all companies are required to prepare a transfer pricing study, as the Miscellaneous Tax Resolution exempts those that do not exceed a certain income threshold from this obligation, as well as from submitting Annex 9 of the DIM.1.
Given this criterion, many companies that are exempt from preparing the study may consider that they do not need to analyze their intercompany transactions in terms of transfer pricing. However, it is important to remember that the obligation to use market values continues to exist regardless of whether or not the formal preparation of the study is required.
From our perspective, although a company is not required to submit a transfer pricing study, it is advisable to obtain an external opinion validating that the consideration used complies with market values. This allows companies to reduce risks in the event of a review by the tax authority and avoid potential adjustments and penalties for non-compliance.
Having external validation also provides greater documentary support in the event of a SAT audit. Correct transfer pricing not only helps mitigate tax contingencies but also ensures better financial planning and regulatory compliance.
In conclusion, although legislation exempts some companies from conducting a transfer pricing study, this does not mean they can freely set their prices without considering market value. Therefore, we recommend that companies not required to conduct this study obtain an external opinion validating their intercompany transactions' compliance with the arm's length principle. In the long term, this represents a key preventive strategy for avoiding tax issues and optimizing risk management.
At CB Strategy, we not only prepare transfer pricing studies, but we can also assist companies that are not required to have one in preparing an opinion, based on economic studies of transactions between related parties, determining whether said transactions were agreed upon with consideration at market value.
1 Accumulable income in the immediately preceding fiscal year is equal to or greater than $13,000,000 for business activities, or $3,000,000 in the case of professional services.
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