Evaluation and structuring of operating models, emphasizing value drivers and tax results

Planning, review, analysis, and evaluation of intercompany operations carried out by the company (taxpayer).

Why is it necessary?

It is not a tax obligation, but it is recommended with the objective of having a structured planning of the Group’s intercompany operations.

Scope

Functional Analysis and Information Gathering: This analysis collects strategic information (financial, contractual, and operational) through functional interviews to thoroughly understand the functions and risks of each transaction. The objective is to validate facts, mitigate risks, and ensure that the transfer pricing structure is transparent and strictly compliant with regulations.
Transfer Pricing Analysis: This analysis identifies internal and external comparables following the hierarchy of the LISR (Mexican Income Tax Law) and OECD guidelines. Through a specialized benchmark, comparability adjustments, and the calculation of profitability margins, it ensures that related-party transactions remain within market ranges and in full regulatory compliance.
Deliverables: The Benchmark Analysis monitors and anticipates adjustments in intercompany operations through a detailed functional study, ensuring strict compliance with articles 76, 179, and 180 of the LISR regarding transfer pricing.

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Frequently Asked Questions

What is the benefit of evaluating my operating model beyond tax compliance?

In addition to ensuring compliance with the LISR and OECD guidelines, this service identifies which areas of your company are generating real value. This allows you to align your intercompany operations with your business strategy, optimizing profitability and eliminating operational inefficiencies that could be affecting your margins.

How do you determine if my current structure is adequate for the authorities?

We conduct functional interviews and a specialized benchmark analysis. We compare your profit margins and prices with those of independent companies under similar conditions. If we detect discrepancies, we anticipate preventive adjustments so that, in the event of a review, your structure is defensible and transparent.

What are "value drivers" and why are they important in this analysis?

Value drivers are the critical functions or unique assets that grow your business (such as proprietary technology or specialized logistics). It is vital that tax and operational benefits are located where the activity truly occurs. If the operating model does not reflect this, the authority could question the deductibility of your transactions.

What do I receive as a final result of this consultancy?

You receive a comprehensive diagnosis that includes the validation of operational facts, an analysis of detected risks, and a detailed functional study. This deliverable serves as a roadmap for implementing strategic changes, ensuring compliance with articles 76, 179, and 180 of the LISR, and strengthening your position against potential audits.