Meet your tax obligations in related-party transactions with technical documentation, defensible analysis, and specialized support.
What Your Company Needs to Keep in Mind in Mexico
Tax Authority
Transfer pricing compliance is reviewed by the Tax Administration Service (SAT).
Companies with transactions between related parties may be subject to supporting documentation requirements, such as Annex 9 of the DIM, the Local Informative Return, the Master File, the Country-by-Country Report, the ISSIF, or a Tax Opinion, as applicable.
Key Obligations
A lack of supporting documentation may result in fines, tax adjustments, denial of deductions, or increased exposure to audits by the tax authority.
Non-compliance Risks
For the immediately preceding fiscal year, the main compliance deadlines in Mexico are:
March 31: Annual tax return for corporations.
May 15: Annex 9 of the DIM and Local Informative Return for Related Parties.
December 31: Master Informative Return and Country-by-Country Report, where applicable.
Functional analysis of functions, assets, and risks.
Description of intercompany transactions.
Identification of the related parties involved.
Financial information on the taxpayer and the transactions analyzed.
Elements typically included in the analysis
In Mexico, taxpayers who engage in transactions with related parties must demonstrate that their revenues, deductions, and consideration were agreed upon in accordance with the arm’s-length principle; that is, under conditions comparable to those that would have been used by independent parties.
Transfer pricing documentation helps demonstrate the reasonableness of intercompany transactions, support the deductibility of expenses, meet regulatory requirements, and reduce risks during tax audits.
Compliance in Mexico involves documenting, justifying, and retaining evidence
Review of contracts, invoices, and supporting documentation.
Selection of the applicable transfer pricing method.
Benchmarking or comparability analysis, when applicable.
Conclusion regarding compliance with the arm’s-length principle.
Download the Transfer Pricing Compliance Roadmap for Mexico
Review in a single document the key steps, deadlines, and obligations your company must address to properly comply with Mexican regulations.
Before ensuring compliance in Mexico, check to see if you have:
Clear identification of transactions between related parties.
Contracts, invoices, and supporting documentation.
A functional analysis of the entities involved.
Up-to-date and segmented financial information.
Benchmarking or comparability analysis, when applicable.
Consistency between intercompany policy and the group’s actual operations.
Leaders in Transfer Pricing Advisory Services in Latin America
Our team can assist you in reviewing, preparing, or strengthening your transfer pricing documentation in Mexico, taking into account local regulations and your business group’s actual operations.
Local Documentation
Benchmarking
Review of Intercompany Policies
Support during audits or in response to regulatory requests
We assist business groups with operations in various countries across the region, combining local compliance, a regional perspective, and specialized technical support.
+1,200
Annual Studies
Why Choose Grupo Consultor EFE® for Your Transfer Pricing Compliance
Experience in documenting and analyzing intercompany transactions.
+600
clients
Support for local businesses, business groups, and companies with international operations.
Support in Mexico and other Latin American countries for companies with multinational structures.
Integrated Vision
Local + Regional
Technical + Strategic
Differentiated
Documentation prepared to comply with, support, and defend the transaction during audits.
At Grupo Consultor EFE®, we understand that transfer pricing compliance is not merely a tax obligation. It can also serve as a tool to strengthen decision-making, assess the efficiency of intercompany transactions, and anticipate risks in an increasingly regulated environment.
The support they provide throughout the entire process is consistent and highly responsive. Their commitment to completing each stage is evident, as is the high level of professionalism with which they approach every project. Their approach builds trust from the start, and the results clearly reflect their serious and responsible approach. The way they engage and deliver on their promises is truly exemplary.
Companies That Have Placed Their Trust in Us
Real results from business groups that demonstrate their compliance with our technical support.
Rosa Delia Silva Pineda
Flextronics
"
Working with your team has been a positive experience from start to finish. From our very first contact, they demonstrated a high level of professionalism, attention to detail, and clarity in communication. The results we achieved were fully in line with our expectations, which confirms the quality and effectiveness of your services.
Argentina Hidalgo
EMASAL Group
"
It was my first time working on transfer pricing; the support and follow-up were excellent and appropriate. At our corporate office in San Diego, we were asked to conduct a transfer pricing study; previously, our company’s accounting functions were handled by an external firm, and they were the ones who recommended Grupo Consultor EFE® to us.
Pablo Rafael Xep
CPS
"
Transfer pricing regulations in Mexico are primarily set forth in the Income Tax Law, the Federal Tax Code, and provisions related to supporting documentation, informative returns, and transactions between related parties.
These rules establish the obligation to price intercompany transactions in accordance with the arm’s-length principle, maintain supporting documentation, and file informative returns when the taxpayer falls under the applicable circumstances.
Transfer Pricing Regulations in Mexico
The Income Tax Law sets forth various obligations for taxpayers who engage in transactions with related parties. Among the most relevant provisions are Article 76, concerning supporting documentation and reporting obligations of corporations; Article 76-A, concerning informational returns for related parties; and Articles 179 and 180, which establish comparability criteria and accepted methods for determining prices or consideration in accordance with market values.
Applicable Legislation in Mexico
Federal Tax Code
Customs Law
Income Tax Law
Resources
Definition of a Related Party in Mexico
Generally speaking, two or more persons are considered related parties when one participates directly or indirectly in the management, control, or capital of the other, or when a person or group of persons participates directly or indirectly in the management, control, or capital of both.
There may also be cases of related-party relationships under customs legislation, as well as transactions with entities subject to preferential tax regimes that must be analyzed with special care.
Supporting Documentation
Taxpayers conducting transactions with related parties must obtain and retain documentation demonstrating that their transactions were agreed upon in accordance with prices, amounts, or margins that independent parties would have used in comparable transactions.
This documentation may include a functional analysis, financial information, contracts, invoices, comparables, the selected method, and technical conclusions supporting the reasonableness of the transactions.
Transfer Pricing-Related Filings
In Mexico, there may be various reporting obligations related to transactions between related parties, depending on the taxpayer’s profile, type of transaction, income, and applicable assumptions.
Among the main filings are Annex 9 of the Multiple Informative Return, the Local Informative Return, the Master Informative Return, and the Country-by-Country Informative Return.
Deadlines:
Transfer Pricing Methods
Mexican regulations provide for various methods to assess whether transactions between related parties are conducted in accordance with the arm’s-length principle.
Accepted Methods:
The selection of the method should take into account the nature of the transaction, the availability of comparable information, the functions performed, the assets used, and the risks assumed by the parties involved.
Penalties for Noncompliance
Noncompliance with transfer pricing regulations may result in fines, aggravating factors, tax adjustments, disallowance of deductions, surcharges, interest, or increased exposure to audits by the tax authorities.
A lack of documentation, the submission of incomplete or erroneous informational returns, or the absence of sufficient supporting evidence to demonstrate market values can increase the taxpayer’s tax risk.
Check your company’s compliance
in Mexico
Schedule a consultation with our team to find out if your related-party transactions have the necessary technical support to ensure proper compliance in Mexico.
Office Mexico
Av. Paseo de la Reforma 222, Piso 1, Col. Juárez, Del. Cuauhtémoc, CDMX, 06600
Office Tijuana
Misión de San Javier 10643, Piso 4, Col. Zona Urbana Río Tijuana, Tijuana, B.C., 22030
Office Guadalajara
Puerta de Hierro 5153, Piso 2,
Col. Puerta de Hierro,
Zapopan, Jalisco, 45116
Office Monterrey
Av. Real de San Agustín 301, Int. 9, Col. Zona San Agustín,
San Pedro Garza García, N.L., 66278
Office USA
600 B St, Suite 300,
San Diego, CA 92101
+52 (55) 1253 7448
+1 (619) 853 1700
info@gcefe.com
