Intercompany transactions and the market value trap The most important obligation of taxpayers under transfer pricing regulations is to demonstrate that the transactions were conducted in accordance with the “arm’s length” principle, which is based on Article 9 of the Model Tax Convention of the Organization for Economic Cooperation and Development (OECD), as follows: “If
Highlights of the International Taxation and Transfer Pricing Conference Series On March 8, 2024, the VI Cycle of Conferences on International Taxation and Transfer Pricing took place, with the participation of some of the most prominent professionals in the field worldwide. Led by our partner, Jesús Aldrin Rojas M., we were able to learn first-hand
The use of Artificial Intelligence in the SAT 2024 Master Plan B.Acy. and LL.B. Miguel Ángel García Piña International Tax Associate at QCG Transfer Pricing Practice S.C. On January 22, 2024, the Tax Administration Service (SAT) announced the Master Plan 2024, through which it informs the strategies it will implement to achieve its revenue objectives
Implications of Synergies in Asset Valuation and Arm’s Length Principle Compliance It has been common to consider that market prices, and even the application of widely accepted “fair” asset valuation methods, are sufficient to comply with the arm’s length principle. However, this is not necessarily the case, as there are economic phenomena, such as synergies,
