In recent years, the Tax Administration Service (SAT) has intensified its tax auditing strategies regarding transfer pricing, reflecting an evolution towards more sophisticated and proactive schemes.
Evolution and Scope of Tax Auditing
- While initially these actions focused primarily on large multinational taxpayers, today they also strongly encompass Mexican business groups.
- This change responds to a more comprehensive vision of tax control, seeking to close compliance gaps at all corporate levels.
- The trend indicates that the SAT will continue to strengthen its auditing capabilities, both in the international context and within the national corporate environment.
Tools and Technology
- The SAT has incorporated advanced technological tools and risk analysis based on big data.
- Automated information cross-referencing is used to detect inconsistencies and aggressive tax planning schemes more effectively.
- The use of invitation letters and electronic reviews has increased, demonstrating a shift towards more agile and selective audits that aim to correct omissions without the need for lengthy formal processes.
Recommendations for Business Groups
Business groups operating in Mexico (multinational or domestic) must prepare for increasingly rigorous scrutiny, which demands:
- Robust documentation.
- A transparent tax strategy.
- Timely compliance.
Note: Anticipating potential observations and aligning internal structures with best practices in transfer pricing is essential to mitigate risks and build a collaborative relationship with the tax authority.
Contact and Consulting
At AGD Global Advisors, we are at your service to support you. For any questions, please contact:
- Roberto González (CEO and Transfer Pricing Partner)
- Emilio Camero (Transfer Pricing Partner)
