Transfer Pricing
Our services comprehend the preparation of transfer pricing studies for operations between both national and international groups, providing support to our clients for the preparation and filing of reports and statistical tax returns required by law.
Likewise, we provide assistance to determine an appropriate arm's length price and/or to review transfer pricing studies previously elaborated.
- Development and implementation of transfer pricing policies
- Assessment of the financial and fiscal impact of transfer pricing policies
- Review and alignment of transfer pricing policies in intercompany contracts
- Preliminary review (diagnostics) of intercompany transactions in order to avoid any trades outside the range of market values or to avoid "last minute" adjustments
- Determination of potential transfer pricing adjustments and compliance with the Miscellaneous Transfer Pricing Adjustment Rule.
- Value Chain Analysis and Identification of Value Creation
- Análisis de la cadena de valor e identificación de la creación de valor.
- Restructuring of intercompany operations in conjunction with their functions, risks and assets
- Generation of policies or compensation for intercompany operations
- Restructurings that imply fiscal and financial efficiency of the national or multinational group
- Preparation of transfer pricing studies (Article 76, sections IX and XII and Article 110 of the Income Tax Law)
- Filling out Annex 9 of the Multiple Informative Return (Article 76, section X and Article 110, section X of the Income Tax Law)
- Filling out transfer pricing annexes of the Information on Tax Status (ISSIF) (Article 32-H of the Federal Tax Code)
- Filling out SIPRED transfer pricing annexes (Article 32-A and 52 of the Federal Tax Code)
- Filling out transfer pricing annexes of the Informative Declaration of Relevant Transactions (Article 31-A of the Federal Tax Code)
- Preparation and submission of the Master Informative Statement of Related Parties (Article 76-A, section I of the LISR)
- Preparation and submission of the Local Information Declaration of Related Parties (Article 76-A, section II of the LISR)
- Preparation and submission of the Country-by-Country Information Statement of Related Parties (Article 76-A, section III of the LISR)
- Determination of the market value, from a transfer pricing perspective, of a company's shares.
- Determination of the market value, from a transfer pricing perspective, of a company's intangible assets.