Transfer Pricing compliance in Mexico is crucial for tax transparency and to avoid penalties. Due to evolving tax regulations, multinational companies must be aware of the deadlines and key requirements for the fiscal year 2024.
Essential Obligations for 2025
According to the CFF (Código Fiscal de la Federación – Federal Tax Code), companies must file several Transfer Pricing annexes. One of the most relevant due dates is the ISSIF Transfer Pricing Annexes, with a deadline of March 31, 2025.
Key Maturity Schedule
| Type of Obligation | Fiscal Year 2024 | Source | Note | Reference |
| ISSIF Transfer Pricing Annexes | March 31 | Federal Fiscal Code | Article 32 H | FEDERAL FISCAL CODE |
ISSIF Relevance in Transfer Pricing
The ISSIF (Informe de situación Fiscal – Tax Situation Report) is a requirement for certain taxpayers exceeding specific income thresholds. This report must include detailed information on related party transactions, ensuring compliance with the Arm’s Length Principles.
Key Compliance Considerations
- Supporting documentation: Companies should have up-to-date Transfer Pricing studies to support the terms of their intercompany transactions.
- Deadline review: Failure to meet deadlines can result in significant fines.
- Regulatory updates: Keeping abreast of tax reforms and the OECD Transfer Pricing guidelines is essential.
Non-compliance Consequences
Failure to comply with reporting requirements may result in financial penalties and tougher tax audits by the SAT (Servicio de Administración Tributaria – Tax Administration Service).
Final Recommendations
In order to ensure proper compliance:
- Review your intercompany transactions and ensure their proper documentation.
- Consult with Transfer Pricing experts to validate the methodology applied.
- Comply with the established deadlines to avoid penalties.
Ensure compliance with your tax obligations and avoid unnecessary risks. Consult our Transfer Pricing experts for customized advice.
Source: Código Fiscal de la Federación (CFF) and SAT regulations.