Transfer Pricing Adjustments June 30 Deadline - Tax - Mondaq Mexico - Mondaq Business Briefing - Books and Journals - VLEX 684488137

Transfer Pricing Adjustments June 30 Deadline

Author:Mr Jaime Bendiksen
Profession:BéndiksenLaw
 
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As an exception to the rules governing deductions in our Income Tax Law, administrative rules allow taxpayers to increase their deductions as a result of transfer pricing adjustments for year 2016 provided a number of requirements are met, including:

Timely filing the following all tax returns including information returns. Preparing and keeping all documentation and information showing that the original transactions was not at arm's-length. Preparing and keeping a statement, under oath, explaining the reason why the originally agreed prices, consideration or profit margins did not conform to the arm's-length standard. Preparing and keeping a statement, under oath, explaining the consistency or inconsistency (i) of the transfer pricing methodologies applied by the taxpayer and (ii) of the search for comparable transactions or entities, both at least with respect to the tax year immediately preceding the year of the transaction being adjusted. Preparing and keeping all documentation and information to show that in carrying on the transfer pricing adjustment the adjusted transactions considered the prices, consideration or profit margins independent parties would have used in comparable transactions. This documentation and information must include the arithmetical calculation of the transfer pricing adjustment. Keeping on file the invoices corresponding to the original transaction that was adjusted. If the Mexican taxpayer also recognizes accounting book effects for the transfer pricing adjustment, it must, as the case may be, either (i) issue an electronic invoice (CFDI) or (ii) keep the CFDI issued by the related party resident of Mexico or...

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