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Transfer Pricing

We advise our clients in compliance with the regulations on transfer pricing, which requires the taxpayer to hold its transactions with related market value contradictory, establishing him Obligations of documentation and a rigid regime of sanctions in the matter, in case of default.

In our advisory service, we guide not only one our clients on the proper integration of the documentation of Transfer Pricing Studies, otherwise, their advise on the Implementation of: provisions based on facts and real history, optimizing the payment of contributions of our clients, from under the proper and strict implementation of the legal framework in force.

Our specialists provide the following services:

Planning and Risk Assessment

We provide comprehensive advice designed to suit your needs to allow us to solve and, as far as possible, anticipate situations regarding transfer pricing face as a result of their daily operations with related parties. Our methodology takes a strategic approach covering operational and tax planning that helps to minimize the overall tax burden and improve the profitability of transactions.

Preparation of transfer pricing studies.

Safeguarding compliance with the regulations on transfer pricing, which requires the taxpayer to hold its transactions with related parties at market value, establishing him documentation requirements and a rigid regime of sanctions in the matter, in case of default.

We prepare the supporting documentation for transactions between related parties and foreign national

APA's

Once the study of Transfer Pricing concluded, there is the option of submitting it for consideration by the tax authorities for resolution regarding the methodology used; that is, obtain a resolution Early Transfer Pricing (APA's). Our firm assists in obtaining this decision before domestic and foreign authorities.

Determination of "Safe Harbor" Maquiladoras

Our experts in the maquiladora industry support them in meeting the specific tax obligations that this sector has, likewise, will assist the implementation of the administrative facilities maquila program in the form of shelter.

Benefits:
  • Reduction of fines and tax credits.
  • Better control of intercompany transactions.
  • Financial evaluations that help improve business cycles companies.

Counseling and preparation of the Master File, Local File and Country by Country Report

Our specialists assist you in integrating the reports required by the tax authorities arising from the actions contained in the Plan BEPS (Base Erosion and Profit Shifting) issued by the Organization for Economic Cooperation and Development (OECD).

Advice on the integration and completion of the annexes, questionnaires and information returns

Provide assistance and support to our customers in integrating and filling the information to be submitted in annexes and questionnaires to be submitted in fiscal opinion as well as in the formulation of information returns, companies must submit derived from operations with related parties.

Baena Asesores Tributarios // Juan Vazquez de Mella 481 Interior 200 Col. Los Morales Chapultepec Del. Miguel Hidalgo, CDMX C.P. 11510 Tel. +52 (55) 3696 8228 +52 (55) 5370 3524
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