Transfer Pricing

Transfer Pricing Services

Preparation and review of contemporary documentation
  • Local Report.
  • Master Report.
  • Country by Country Report.
  • Intercompany contracts.
  • Calculation of transfer pricing adjustments.
  • Documentation of transfer pricing adjustments.
  • Annexes / Transfer pricing sections of the Tax Opinion / ISSIF.
  • Annex 9 of the Multiple Information Declaration.
  • Local Information Statement.
  • Master Information Statement.
  • Country by Country Information Statement.
  • Informative Declaration of Relevant Operations (format 76).
  • Regional documentation for cross-border jurisdictions APAC, EMEA, NA, and LATAM.
  • Transfer pricing documentation for financial and insurance institutions.
  • Prospective studies for the Hydrocarbon Sector.
  • Identification of permanent establishments.
  • Diagnosis of compliance with transfer pricing obligations.
Consulting and planning
  • Determination of interest rates for financing operations.
  • Determination and implementation of intercompany policies for existing and new operations.
  • Integration of documentary support for prorated expenses.
  • Safe-harbor calculation for maquiladora companies.
  • Optimization of intercompany operations.
  • Valuation of derivative financial transactions.
  • Evaluation and re-evaluation of the business model.
  • Identification and valuation of intangibles.
  • Valuation of shares / equity interests.
  • Supply chain analysis.
  • Business restructuring.
  • Portfolio valuation.
Defense and negotiation in transfer pricing matters with the tax authority
  • Preparation and negotiation of advance transfer pricing agreements.
  • Attention to transfer pricing requirements.
  • Negotiation with the tax authority in transfer pricing audits (from the invitation letter, review and response to the written observations, as well as the tax credit) SAT, PRODECON.
Offer of digital technological tools
  • Implementation of technological tools for compliance with tax obligations (tax symmetry, recording errors and recognition by type of operation.
  • Preparation of intercompany matrices from intercompany billing.
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