Mexico’s transfer pricing regime undergoes its most profound revision since its establishment Background Information One of the most important regimes that the country has at its disposal is the transfer pricing regime. This regime (in force in the country since 1997) seeks that the participants of an intercompany operation transact considering the terms that independent third parties
Considering the complexity of controlling beneficiaries in Mexico The figure of a controlling beneficiary (CB) was included in Mexico’s 2022 tax reform. This was following recommendations made by the Financial Action Task Force (FATF) and the Global Forum on Transparency and Exchange of Information for Tax Purposes (Global Forum) of the OECD. The aim is
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
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
