Transfer pricing
Transfer pricing for well-structured, documented and defensible intercompany transactions.
MSST advises multinational groups, IMMEX companies and businesses with related-party transactions on the design, analysis and documentation of transfer pricing policies. We start with actual operations and functional analysis to select an appropriate methodology, document comparables and support technically sound positions under applicable Mexican tax rules and OECD guidance.
What this practice includes
Transfer pricing studies and Local File
Annual documentation of related-party transactions: functional analysis, method applied, comparables and a conclusion on the arm’s-length range.
Functional and economic analysis
We identify the functions, assets and risks of each entity to characterize it correctly and choose the right method.
Comparable searches and screening
Selection of comparable companies and transactions using documented, reproducible criteria, with comparability adjustments where needed.
Intercompany financing, services, royalties and purchases or sales
Analysis of loans, service charges, use of intangibles and sales of goods between group entities.
Information returns and related obligations
Preparation of the related-party information filed with the tax authority.
Master File and Country-by-Country reporting, where applicable
We assess whether the group is required to file and coordinate the corporate and jurisdiction-level information these reports need.
Technical support during tax authority reviews and requests
We prepare the technical response and supporting documentation, and support the client throughout the review.