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Related parties · Transfer pricing

Do you invoice companies in your own group? Show it was at market value.

The Income Tax Law requires related-party transactions to be priced at market value and, in many cases, documented and reported. Without support, the SAT can adjust your prices and assess tax differences, surcharges and penalties.

  • Obligation review: whether you're required and what level of documentation you need
  • Study with functional analysis, comparables and a transfer pricing method
  • Support with filings on related-party transactions filed with the SAT

Service in Spanish and English · Confidential

Related-party analysisIllustrative example
OperationsServices to a U.S. subsidiary
Annual amountMXN $18 million
Current transfer pricing studyNone
Related-party information returnPending
Margin vs. comparablesBelow the range
Next stepFunctional analysis and comparables
If the margin falls outside the arm's-length range, the SAT can adjust it. Document on time lets you correct things before an audit.
Calculators

Does it apply to you, and what it would cost you not to have it?

First check whether you're required to document your related-party transactions. Then calculate the adjustment if your margin falls outside the arm's-length range (art. 180 Income Tax Law).

Does documentation apply to you?

Prior-year revenue, for the whole company.

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If your margin is out of range

If it falls outside the interquartile range, the law adjusts it to the median (art. 180 Income Tax Law).

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For guidance only. The exemption thresholds (around $13 million for business activities and $3 million for professional services) are updated; even if exempt, you must deal at market value. The adjustment uses a 30% income tax rate and excludes inflation adjustments, surcharges and penalties.

What you risk without documentation

Without support, the authority decides what the price was

1

Adjustments to your prices

If you can't show the price was at market value, the SAT can adjust it and assess the income tax difference, with inflation adjustments and surcharges.

2

Penalties for filings

Not filing, or filing with errors, the related-party information return triggers penalties under the Federal Tax Code.

3

Auditors, banks and investors

Your external auditor, a bank or an investor will ask for support for transactions between group companies. Without it, the process gets complicated.

What's included

A study that holds up to your auditor and the SAT

1

Functional and risk analysis

We document the functions, assets and risks of each related party. It's the basis to justify the margin.

2

Comparables search

We use specialized databases of comparable companies, not general internet searches.

3

Method and arm's-length range

We select the applicable method and determine the arm's-length range. If your margin falls outside it, we calculate the adjustment.

4

SAT filings and documentation

We support you with the related-party information return and, when your size requires it, with the local and master file under art. 76-A.

How we work

Clarity before selling

We'll tell you if it's not right for you

If the assessment shows you don't need the service, we'll tell you and point you to what you do need.

15+ years of experience

Accounting, tax and finance for entrepreneurs, SMEs and foreign companies operating in Mexico.

100% online, anywhere in Mexico

We work by video call and WhatsApp. You send the information; we take care of the rest.

Included · AO INSIGHT portal

Your numbers and your to-dos, in one place

Calendar of transfer pricing obligations and alerts for related-party transactions detected in your books.

See how your numbers would look
Process

From review to delivered study

STEP 1

Obligation review

In 30 minutes we review your related-party transactions and your group structure.

STEP 2

Fact-finding

Interview with your finance team, review of intercompany agreements and financial statements.

STEP 3

Analysis

Comparables, method, arm's-length range and adjustment calculation if applicable.

STEP 4

Delivery and updates

Signed study, support with SAT filings and annual update.

Free assessment

Review of your obligation in 30 minutes. No cost.

We tell you whether you're required, what level of documentation applies to you and what risks we see today. If you don't need it, we'll tell you and won't sell you a study.

  • If you're required to document
  • Which transfer pricing method would apply
  • Calendar of SAT obligations

Prefer to pick a day and time? Book a 30-minute video call.

Transfer pricing review

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Frequently asked questions

What clients usually ask us

When am I required to document?

Generally, if you have related-party transactions. The law exempts from documentation those whose prior-year revenue was below certain amounts (around $13 million for business activities and $3 million for professional services), unless they deal with preferential tax regimes

Do I need a local and master file?

Only if you meet the conditions of art. 76-A, for example because of your revenue or because you belong to certain groups. Most SMEs don't; if it applies to you, we include it.

What if I'm audited and don't have a study?

The SAT can determine the market price of your transactions and charge you the income tax difference, with inflation adjustments, surcharges and penalties. Having the study lets you defend your prices with arguments.

Do you work in English?

Yes. We work with foreign groups and their auditors, and can deliver reports in English.

How much does it cost?

It depends on the scope and the information you already have. After the assessment we send a written proposal with a fixed fee and no hidden charges.

Transfer pricing

Document your transactions before they're reviewed

30-minute assessment at no cost. If it's not right for you, we'll say so.

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