IRS-SAT renew the Qualified Maquiladora Approach Agreement for the second time For the second time, the Mexican tax authority, Servicio de Administración Tributaria (SAT) and the Internal Revenue Service (IRS) of the United States of America have renewed the Qualified Maquiladora Approach (QMA) Agreement, with the goal to avoid double taxation for U.S. taxpayers with
How to avoid risks of recharacterization or disregard of intercompany transactions? In the day-to-day operations of a multinational group, it is common for related parties within the group to engage in various types of transactions. Purchases, sales, licensing, services, and financing are part of daily operations. But what happens when these transactions are incorrectly characterized
Intercompany transactions and the market value trap The most important obligation of taxpayers under transfer pricing regulations is to demonstrate that the transactions were conducted in accordance with the “arm’s length” principle, which is based on Article 9 of the Model Tax Convention of the Organization for Economic Cooperation and Development (OECD), as follows: “If
Highlights of the International Taxation and Transfer Pricing Conference Series On March 8, 2024, the VI Cycle of Conferences on International Taxation and Transfer Pricing took place, with the participation of some of the most prominent professionals in the field worldwide. Led by our partner, Jesús Aldrin Rojas M., we were able to learn first-hand
