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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
An overview of BEPS controversies in Mexico In 2013 the Organization for Economic Development and Coordination (OECD) together with the countries that are part of the G20 (including Mexico) began the development of the action plan vs t base erosion and profit shifting (BEPS). The goal of the BEPS plan is to ensure that profits
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