Transfer pricing
Transfer pricing studies
If your company buys, sells, provides or charges for services with companies in its own group, the SAT (Mexico’s tax authority) checks that those prices match what independent parties would agree. We document your transactions so you can prove it.
Tell us about your case
A partner will reply, in English or Spanish.
Transfer pricing
Who it’s for
- Mexican subsidiaries of groups headquartered in the US, Europe or China
- Mexican groups with several companies that transact with each other
- Companies that pay royalties, interest or service fees to related parties
- Companies under SAT review of their intercompany transactions
Transfer pricing
What’s included
We prepare the studies under Mexican law, using comparables databases.
-
Transfer pricing study
We analyze your related-party transactions and document that your prices and amounts are at arm’s length.
-
Local File and Master File
We prepare the Local File and the Master File, the documentation authorities require on the local entity and on the group.
-
Country-by-Country Report
We support the Country-by-Country Report when the group is required to file it.
-
Comparables search
We use specialized databases to find comparable transactions and companies, even in unusual cases.
Transfer pricing
How we work
- 1
Group transactions
Together we identify your related-party transactions and their amounts.
- 2
Functional analysis
We understand the functions, assets and risks each group company takes on.
- 3
Method and comparables
We choose the method and find comparables for each type of transaction.
- 4
Study and documentation
We deliver the study and the documentation, ready to file or keep on record.
Frequently asked questions
What is transfer pricing?
It is the prices that companies in the same group charge each other, for example a Mexican subsidiary and its parent. The law requires them to match what two independent companies would agree in a comparable transaction. This is known as the arm’s length principle.
Who needs a transfer pricing study?
Broadly speaking, companies with related-party transactions, especially with foreign residents. The law exempts certain taxpayers based on their size and type of transaction. We review your case and tell you what applies.
What is the difference between the Local File and the Master File?
The Local File documents the Mexican company’s transactions with its related parties. The Master File describes the whole group: its structure, its business and its transfer pricing policy. They are two separate documents, with different filers.
What happens if I don’t have the documentation?
If the SAT concludes your prices are not at arm’s length, it can adjust them and assess unpaid taxes, plus penalties, interest and inflation adjustments. Having the study doesn’t prevent an audit, but it gives you the support to defend your numbers.
Related
Related services
-
International tax
Tax treaties, double taxation and cross-border transactions, in English or Spanish.
Learn more -
Business and intangible asset valuation
Value of businesses, assets and intangibles for acquisitions, mergers and shareholder agreements.
Learn more -
Doing business in Mexico
For parent companies setting up in Mexico: structure, taxes and reporting in English.
Learn more
Do you transact with companies in your group?
Tell us what transactions you have. We’ll tell you what documentation you need.