Transfer Pricing

Transfer Pricing ensures that transactions between related parties comply with tax and market criteria, minimizing risks, strengthening financial transparency, and ensuring documentation aligns with national and international regulations.

Why is it necessary?

It is an annual obligation set out in Article 76, sections IX, XII and XIII of the Income Tax Law: every company with related-party transactions must demonstrate that they were carried out at market values. Beyond compliance, the study is the first line of defense in an audit: without it, the authority may determine prices at its own discretion and disallow deductions.

Scope

TP Documentation
Valuation of shares, businesses, and intangibles
Evaluation and structuring of operating models, emphasizing value drivers and tax results
- Operating Model Diagnosis
- TP Risk Assessment
- Restructuring of Intercompany Operations
- Financing Structure Analysis
Defense in TP Audits, Controversies, MAPs, and APAs

Related Consultants

Roberto González Morelos

Transfer Pricing

José Luis Parada

Transfer Pricing

Jorge E. Castellón

Transfer Pricing

Emilio Camero Luna

Transfer Pricing

Frequently Asked Questions

Are all companies required to comply with Transfer Pricing regulations?

Companies that conduct transactions with domestic or foreign related parties generally must document and demonstrate that their transactions were carried out at market values.

What are the risks if a Transfer Pricing study is not prepared?

Fines, tax adjustments, surcharges, and challenges during audits. The lack of adequate documentation can be interpreted as deliberate non-compliance by the authorities.

How often should the Transfer Pricing study be updated?

Typically, every fiscal year, as authorities require current documentation consistent with the economic conditions of the evaluated period.

Does the Transfer Pricing study only apply if I have operations with foreign companies?

Not necessarily. Although its origin is international, in many legislations (such as Mexico’s), it is also mandatory to document transactions between domestic related parties. If two or more companies share the same partners, management, or control, any transaction between them (loans, services, sales) must be supported by a study demonstrating that it was agreed upon at market prices, just as it would be with an independent third party.