On October 2, 2026, the Tax Administration Service (SAT), the Mexican National Customs Agency (ANAM), and the Agency for Digital Transformation and Telecommunications (ATDT) extended the deadline for filing the Electronic Declaration of Value (MVE) until October 31. This extension offers importers who purchase from related parties an opportunity to review more than just a customs procedure: it allows them to verify the consistency between the value declared to customs and the Transfer Pricing technical study that supports their intercompany policy.
Both systems examine the same transaction from different perspectives. Customs seeks to correctly determine the value of imported goods, while the Income Tax (ISR, by its acronyms in Spanish) seeks to determine whether the deducted cost corresponds to the terms of the transaction. When the importer declares in the MVE that there is a relationship with the seller, the two assessments are recorded side by side.
What is the MVE, and what changes with the extension?
The MVE is the electronic declaration through which the importer provides the information supporting the customs value of their goods. It is based on Article 59, Section III, of the Customs Law, which requires the importer to submit a declaration containing the information necessary to determine the customs value and to retain the corresponding documentation.
The MVE includes, among other details, the valuation method, the price paid or payable, add-on items, items not included in the value, and whether there is a relationship between the buyer and seller. Additionally, it indicates whether such a relationship influenced the transaction value.
According to the official statement, this expansion was included in the first draft of the Third Resolution Amending the General Rules of Foreign Trade for 2026.
Starting November 1, 2026, the gradual transition to submission via the Single Window, by customs regime, will begin and continue through January 15, 2027. The change provides operational flexibility; however, it does not modify the documentation the importer must provide.
Where do customs value and Transfer Pricing Meet?
Article 64 of the Customs Law establishes that, as a general rule, customs value is based on the transaction value—the price paid for the goods, adjusted where applicable under Article 65.
Article 67 conditions the acceptance of this value on specific requirements, notably that no related-party relationship exists or, if one does, that it has not influenced the transaction price. Article 68 defines related parties, including relationships established through direct or indirect control or an equity interest of 5% or more, as specified by law.
In Transfer Pricing, this same transaction is evaluated under the arm’s-length principle of the Income Tax Law. The primary distinction lies in the unit of analysis:
| Customs Value | Transfer Pricing | |
| Key Question | Is the declared price undervalued? | Is the deducted cost overstated? |
| Analysis unit | Each import transaction | Often, the institution’s annual margin |
| Time | Upon shipment of the goods | At the end of the fiscal year |
| Outcome | That the association did not influence the price | That the result falls within the range of full competition |
A study that supports an operating margin using the Transactional Net Margin Method does not prove, by itself, that each unit price declared to customs was not influenced by the related-party relationship. It can provide useful information about the circumstances of the sale, but it answers a different question.
Royalties are another sensitive issue. In customs, royalties related to goods may be considered an add-back under Article 65, provided the conditions set forth in that article are met. In Transfer Pricing, they are typically analyzed as a separate transaction. If the importer does not treat them consistently, the MVE and the Local File may describe the same business relationship in two different ways.
What happens when Transfer Pricing adjustments are made?
The most visible tension arises with year-end adjustments. Many policies set provisional prices during the fiscal year and adjust them at year-end to bring the distributor’s margin within the range of full competition. This adjustment can change—after shipment—the price initially reported in the MVE.
The effects depend on the direction of the adjustment:
Upward adjustment (the importer pays more to its related party): the cost for income tax purposes increases, but it must be determined whether the adjustment involves an actual change in the price paid or payable for the goods and, consequently, whether it affects the customs value.
Downward adjustment (the importer receives a refund): the cost for income tax purposes decreases, while it must be analyzed whether the adjustment effectively modifies the price of the goods and whether there is any corresponding effect on the customs value.
In both cases, the importer must be able to explain why the declared value and the deducted cost do not match, and whether or not the adjustment affects the transaction value. That explanation is stronger when the intercompany policy, contracts, and MVE are drafted with the same logic from the outset, rather than being reconciled only when an audit occurs.
Extending the deadline to October 31 does not change this analysis. However, it does provide time for the foreign trade and tax departments to jointly review how the related-party relationship will be declared in the MVE and what documentation supports it.
At TPC Group, in every analysis of imports between related parties, we evaluate the consistency between the Transfer Pricing policy, the closing adjustments, and the value declared to customs. Our goal is help importers support both, their deductible cost and the transaction value, of their goods using the same technical logic.