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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 The IDC Â 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 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
One of the novelties resulting from the OECD/G20 action plan vs. base erosion and profit shifting (the BEPS plan) is the suggestion of a safe harbor in relation to low value-added intercompany services. Said safe harbor, under certain limitations, would enable the transfer of certain types of support services (not associated in any way to