Mexico: SAT Increases Transfer Pricing Collection from Large Taxpayers by 367%

June 11, 2025

The SAT (Servicio de Administración Tributaria – Tax Administration Service) of Mexico has achieved a significant increase in tax Transfer Pricing collection, demonstrating a more rigorous strategy for auditing large taxpayers. 

Notable Increase in Collection

Between 2019 and 2024, the SAT collected 106.178 million pesos in Transfer Pricing, which increased by 367% compared to the 28.966 million collected in the 2013-2018 period due to the implementation of more efficient procedures and the strengthening of tax audits. 

Analyzed Economic Sectors

In the last year, Transfer Pricing audits led large taxpayers, particularly 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. 

SAT Strategies

In order to achieve these results, the SAT established specialized Transfer Pricing to prevent misshift profits to other tax jurisdictions. Additionally, the Master Plan guidelines have been followed, enabling the tax authority to operate under international Transfer Pricing standards efficiently. 

Implications for Multinational Companies

This increase in revenue 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 penalties and significant tax adjustments. 

Is your company 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 customized consultation. 

 

Source: Gob.mx

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