According to recent data published by the Mexican Tax Administration Service (SAT), from 2019 to 2024, tax revenue efficiency derived from Transfer Pricing audits on large taxpayers invoiced to more than MXN 106.18 billion. This figure represents a 367% increase compared to the period from 2013 to 2018, when approximately MXN 19 billion were collected under the same concept.

The SAT has emphasized the importance of these audits in key sectors of the economy, such as the automotive, mining, electronics, and telecommunications industries, which corrected their tax situation by more than MXN 19 billion. It also highlights the role of the SAT´s specialized unit, which seeks to prevent the improper shifting of profits to low-tax jurisdictions, thereby safeguarding income tax (ISR) revenue.

Why Is This Significant?

Most large taxpayers are part of multinational enterprise (MNE) groups with operations in Mexico. Consequently, the timely preparation of Transfer Pricing documentation is essential. This documentation must adequately address elements such as the materiality of transactions in order to provide economic substance and ensure full compliance with the applicable Transfer Pricing regulations.

J.A. DEL RÍO offers a wide array of specialized consulting services to assist you with these and other matters, in order to ensure that your project complies with the applicable characteristics  contained in this agreement.

If you have any questions, J.A. DEL RÍO can provide you with our experts to advise in matters concerning compliance with your legal and tax obligations. Once again, please let us know if we may be of any further assistance to you at: contacto@jadelrio.com