Considering the complexity of controlling beneficiaries in Mexico 

Considering the complexity of controlling beneficiaries in Mexico The figure of a controlling beneficiary (CB) was included in Mexico’s 2022 tax reform. This was following recommendations made by the Financial Action Task Force (FATF) and the Global Forum on Transparency and Exchange of Information for Tax Purposes (Global Forum) of the OECD. The aim is

Brief tax alert on the possible effects in the reconfiguration of internal service provider (insourcings) company’s business structures from the initiative to reform subcontracting and outsourcing rules in Mexico.

Brief tax alert on the possible effects in the reconfiguration of internal service provider (insourcings) company’s business structures from the initiative to reform subcontracting and outsourcing rules in Mexico. Addressing the reform initiative to modify the rules on subcontracting and outsourcing presented the past December 12 by the Federal Executive to modify the Federal Labor

Location impact on profit margins: Developed countries vs Emerging countries.

Location impact on profit margins: developed countries vs emerging countries. In transfer pricing practice is normal that we cannot always find functionally comparable companies located in the same country where analyzed company is, reason why foreign comparable companies are commonly used. According to this, OECD have persistently suggested to apply additional adjustments to include structural

Immediate transfer pricing effects of the Covid-19 pandemic

Immediate transfer pricing effects of the Covid-19 pandemic At the beginning of 2020, the new virus SARS-CoV-2 (Covid-19) that originated in the city of Wuhan, China surprised the world causing an unprecedented disruption to our modern world.  By the middle of this year the virus has become a global pandemic evolving at a rapid and