The use of Artificial Intelligence in the SAT 2024 Master Plan B.Acy. and LL.B. Miguel Ángel García Piña International Tax Associate at QCG Transfer Pricing Practice S.C. On January 22, 2024, the Tax Administration Service (SAT) announced the Master Plan 2024, through which it informs the strategies it will implement to achieve its revenue objectives
Implications of Synergies in Asset Valuation and Arm’s Length Principle Compliance It has been common to consider that market prices, and even the application of widely accepted “fair” asset valuation methods, are sufficient to comply with the arm’s length principle. However, this is not necessarily the case, as there are economic phenomena, such as synergies,
Simulation of legal acts by operations between related parties A latent risk for taxpayers is the classification of their operations with related parties as simulated operations, which may have implications even of a criminal nature. In this study, we review the assumptions in which taxpayers would be in these circumstances and provide recommendations about the
A perspective on the evolution of transfer pricing regimes in Latin America Background Transfer pricing regimes make their formal appearance in Latin America in the 1990s, where, as a result of the liberalization process of the economies, signing of trade agreements and negotiation of treaties to avoid double taxation it became urgent to establish a
