
Transfer Pricing
Compliance with the Free Competition Principle is one of the most important priorities for tax authorities around the world. Mexico, due to its strong trade relations with the United States, Asia, and Europe, has extensive experience in developing disclosure, compliance, and control schemes related to transfer pricing.
At CB Strategy, we have experts in this field to support our clients in terms of regulation and compliance.
We provide the certainty and assurance that transactions with related parties will be properly supported in the event of any tax dispute.
Regulated by the Income Tax Law, transfer pricing arises from transactions between companies or related parties, which directly impact the competitive market, as well as help prevent risks and achieve planning alternatives.
Our firm offers advice on the duties and other activities that may arise from transfer pricing. Some of the services we offer include:
- Transfer pricing diagnosis (health check).
- Preparation, review and updating of transfer pricing studies.
- Advice on compliance with transfer pricing obligations.
- Documentation, support, and planning studies for transfer pricing.
- Design, analysis and validation of transfer pricing policies.
- Unilateral, bilateral and multilateral advance pricing agreements (APAs).
- Transfer pricing analysis for the maquiladora industry through the development of safe harbor schemes.
- Development of benchmarks to determine the taxpayer's transfer pricing situation.
- Advice on determining transfer pricing policies.
- Advice and support in resolving disputes based on tax treaties entered into by Mexico.
- Advice on the correct completion of information declarations (local, master, and country by country).
- Analysis: commercial reasons and economic consistency in intercompany transactions.
- Preliminary and preventive analysis in operations to be carried out between related parties.
- Completion of annexes reported to the transfer pricing authority, such as ISSIF: Information on Tax Situation; SIPRED: System for the Submission of Tax Opinions; and item 9: Multiple Informative Declaration on transactions with related parties of foreign residents.
- Consulting on inspection processes related to transfer pricing.
- Attention to authority requirements regarding transfer pricing.

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