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BEPS plan Action 13. Country by country report and transfer pricing documentation
New transfer pricing documentation standard One of the most visible actions of the BEPS plan is Action 13 (country by country report and transfer pricing documentation). Action 13 has taken effect, modifying Chapter V of the OECD Transfer Pricing Guidelines (OECD Guidelines) of 2017, and in Mexico, by incorporating article 76-A to the Mexican Income
Intangibles: New BEPS Guidelines
Intangibles: New BEPS Guidelines One of the main concerns of the OECD regarding the mechanisms of base erosion employed by taxpayers has to do with the use of intangibles, in particular regarding the distortion of their value in controlled transactions, or even their strategic allocation in preferential regimes, without considerations of transfer pricing rules that
General considerations for the BEPS plan
What is the BEPS plan?* The BEPS plan (acronym for action plan vs. base erosion and profit shifting) is a response by the G-20 to the aggressive tax practices implemented by some multinational taxpayers in recent years. The BEPS plan is coordinated by the Organization for the Economic Co-operation and Development (OECD) and seeks to
Filing deadline for the transfer pricing informative return (operations with related parties)
On April 13th, the Tax Administration Service (SAT), released the new anticipated version of the miscellaneous tax rules (on its first resolution for 2018), and its appendix 1A. The miscellaneous rules provide the disposition 3.9.18, which grants an extended deadline to June 30, 2018, to file the transfer pricing informative return (appendix 9, operations with
