During “Tax Certainty Day 2025,” the Organization for Economic Cooperation and Development (OECD) recognized the SAT (Servicio de Administración Tributaria – Tax Administration Service) for its progress in managing agreements and resolving tax disputes. This recognition, based on globally comparable metrics, places Mexico among the most reliable jurisdictions for multinationals operating under international Transfer Pricing standards.
The SAT ranked first worldwide in the Age of Inventory category, which measures the age of cases handled through the Mutual Agreement Procedure (MAP). It also ranked second in the APA Most Improved Jurisdiction category, highlighting the improvement in the administration of Advance Pricing Agreements (APA). Both results demonstrate a significant institutional transformation in tax certainty.
A Significant Advance for the Mexican Transfer Pricing Regime
These recognitions confirm that Mexico is progressing toward a more predictable Transfer Pricing regime, aligned with the OECD Guidelines and the expectations of multinational companies. Strengthening SAT processes promotes an environment that resolves international tax disputes more quickly, reducing exposure to double taxation and clarifying the application of the Arm’s Length Principle.
The OECD’s Transfer Pricing Country Profile (July 2025) notes that Mexican legislation directly incorporates the OECD Transfer Pricing Guidelines, which facilitates coordination between tax administrations and taxpayers. Mexico has demonstrated notable progress in MAP procedures and APA management, key elements within Action 14 of the BEPS Project.
Tax Certainty: A Decisive Factor for Multinationals
For companies operating abroad, improvements in the SAT’s dispute resolution mechanisms have strategic implications. A more efficient tax authority reduces uncertainty regarding bilateral adjustments and resolution times, while encouraging greater technical consistency in Transfer Pricing documentation.
This more stable environment encourages multinational groups to review the alignment among their internal policies, the economic substance of their operations, and the information reported in their local studies. Tax certainty thus becomes a differentiating factor in investment decision-making.
A More Strategic Approach to Transfer Pricing Management
The strengthening of the SAT is an opportunity for taxpayers to integrate Transfer Pricing as part of their overall tax strategy. Greater efficiency in MAP and APA means more planned structures, where advance agreements and bilateral resolutions reduce risks and stabilize future tax burdens.
It is especially relevant for industries with complex value chains, intangible-intensive activities, or high-tax-sensitive intra-group transactions.
Mexico as a Regional Benchmark in Transfer Pricing
The OECD’s recognition not only validates the SAT’s administrative efforts but also positions Mexico as a leading jurisdiction in Latin America in Transfer Pricing and tax dispute resolution. Following the global trend driven by the BEPS project, the country is moving towards more transparent and efficient processes comparable to those of advanced economies.
This progress increases the confidence of investors and multinationals, who see Mexico as offering international cooperation and legal certainty.
Conclusion
The progress recognized by the OECD represents a turning point for the Mexican tax system. The combination of a robust technical regime, more efficient resolution mechanisms, and greater alignment with international standards contributes to a transparent and predictable administering scenario for Transfer Pricing.
For large taxpayers, this is a strategic moment to review their policies, strengthen their documentation, and anticipate opportunities within a climate of increasing tax certainty.
Strengthen Your Transfer Pricing Compliance with Specialized Advice
At TPC Group, we have an experienced regional team in international taxation, prepared to optimize your documentation, reduce risks, and ensure the correct application of the Arm’s Length Principle in each jurisdiction where your company operates.
Our comprehensive support helps you make decisions with greater certainty, ensuring regulatory compliance and strategic solutions tailored to the economic situation of your operations.
Contact us for a customized assessment and to determine how we can support your Transfer Pricing management with a technical and highly specialized approach.
Source: Capital México