Mexico’s Tax Administration Service (SAT) has achieved a significant increase in tax revenue related to transfer pricing, demonstrating a more rigorous strategy in the auditing of large taxpayers.
Significant increase in revenue
Between 2019 and 2024, the SAT collected 106.178 billion pesos in transfer pricing, representing a 367% increase compared to the 28.966 billion obtained in the 2013–2018 period. This growth is attributed to the implementation of more efficient procedures and the strengthening of tax audits.
Economic sectors under scrutiny
In the last year, transfer pricing audits led large taxpayers, especially in the automotive, mining, electronics, and telecommunications sectors, to correct their tax situation by more than 19 billion pesos. These actions reflect the SAT’s commitment to ensuring compliance with tax obligations by companies with international operations.
Strategies implemented by the SAT
To achieve these results, the SAT has established a specialized transfer pricing area with the aim of preventing the improper migration of profits to other tax jurisdictions. In addition, the guidelines of the Master Plan have been followed, allowing the tax authority to act efficiently and in accordance with international standards in the regulation of transfer pricing.
Implications for multinational companies
This increase in tax collection underscores the importance for multinational companies to review and strengthen their transfer pricing policies. It is essential to have adequate documentation and tax strategies aligned with current regulations to avoid significant penalties and tax adjustments.
Is TNMM prepared to face transfer pricing audits? At TPC Group, we offer specialized advice to ensure tax compliance and optimize your international operations. Contact us for a personalized consultation.
Source: Gob.mx