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 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
SIPREDÂ [1] 2019. Changes to the transfer price regime. This 20 of January, annex 16 of the Miscellaneous Fiscal Resolution for fiscal year 2020 was published in the Official Gazette of the Federation[2][3], originally published the past 28 of December 2019. This document provides instruction on the integration and the characteristics, the format of the guide
Miscellaneous Fiscal Resolution for 2020 This past 9 January 2020 the Official Gazette of the Mexican Federation[1] published the official modification of annexes 3, 5, 7, 8 and 11 [DSG1]Â of the Miscellaneous Fiscal Resolution[2] for 2020. With regards to transfer pricing, there were no modifications to the regime that could alter taxpayer obligations that carry
