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New rules regarding transfer pricing adjustments (Mexico)

New rules regarding transfer pricing adjustments (Mexico) On June 11, 2018, the Mexican Government released in its Official Diary, the Second Resolution of Modifications to the Miscellaneous Tax Rules 2018 (RMF) with new rules regarding transfer pricing adjustments. These are the following: Rule 3.9.1.1. Concept and scope of “transfer pricing adjustment” in its different modalities.

Highlights from the participation of the Mexican Tax Authorities at the conferences on transfer pricing and international taxation at Universidad Panamericana (UP)

Highlights from the participation of the Mexican Tax Authorities at the conferences on transfer pricing and international taxation at Universidad Panamericana (UP) The panel with SAT Mexico estimated the tax avoidance by multinationals in approximately USD 5 billion per year In July 18, a round of conferences regarding transfer pricing and international taxation took place

Special BEPS Issue, IDC Tax Magazine

Special BEPS issue, IDC Tax Magazine The IDC  tax magazine will publish in June a special number coordinated by our firm on the effects in Mexico of the OECD action plan vs. base erosion and profit shifting (BEPS). This number will include the participation of the Mexican tax authorities, the administrative courts, the taxpayer’s defense

Intercompany operations and contractual terms

Intercompany operations and contractual terms An in-depth consideration regarding substance One of the procedures prior to confirming the arm’s length value of an intercompany transaction is the analysis of contractual terms in the operation. Contrary to what occurs among independent third parties, it is possible that among related parties the incentives to reflect contractual terms