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As of late, Recently, the risk of international companies being audited for transfer price has increased substantially throughout the world, and especially in the Mexico. The current Mexican regulations require that all companies with related-party transactions are required to compile “reasonable and full” documentation of arm’s-length pricing prior to filing annual income tax returns .

Our tax professionals can thoroughly analyze, evaluate and document your methodology for determining the transfer price of products, services and intellectual property transferred between or among your related parties. We provide reports that meet the transfer price documentation required by the SAT.

For the companies looking for a confidence in the future on transfer prices and related taxable income, we strongly recommend clients to secure the Advance Pricing Agreement (“APA”) between SAT and the taxpayers and/or among multiple other taxing authorities and the taxpayers. There are many advantages of securing an APA for multi-national companies. An APA reduces the risk of double taxation, saves costly litigation expenses, eliminates the hassle of transfer price audits, and even resolves the old burdensome tax dispute with the SAT or with other taxing authorities. Not only our experts have the most hands-on APA experience and in-depth knowledge of all aspects of APA, but also our senior staff can provide the APA service to our clients in person at any time.

Maquiladora transformation means that a normal manufacturer, to enjoy the benefit of tax relief for the maquiladora companies, changes its regime to a maquiladora. As the tax benefit is various and significant in Mexico, the authority put many restrictions on converting, operation and even tax declaration. We provide high quality one-stop service from legal to foreign trading compliance services for the maquiladora companies.

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