Preparation and review of transfer pricing studies
Assistance in identifying and evaluating domestic and foreign intercompany transactions; as well as in the documentation of the functions performed, the assets used and the risks assumed in compliance with the Transfer Pricing Guidelines of the OECD and the proposals contained in the BEPS Plan
Multinationals and Tax Administrations, approved by the Council of the Organization for Economic Cooperation and Development and the provisions of the plan for the "Erosion of the tax base and transfer of profits" (BEPS - Base Erosion and Prot Shifting).
Perspective analysis for the implementation of new operations with related parties, national and/or abroad. Validation and analysis of transfer pricing policies of multinational companies
Advice on the completion and/or preparation of the annexes corresponding to transfer prices in the Information on the Tax Situation (ISSIF), and annexes of the Opinion of the Financial Statements for tax purposes (Fiscal Opinion or SIPRED
Advice on filling out and/or preparing Annex 9 – Information on operations with related parties residing abroad of the Multiple Informative Declaration
Advice on the completion and/or preparation of the Informative Declarations of related parties: Master (Master File), Local (Local File) and Country by Country (Country by Country).
Advice and/or assistance in consultations related to the methodology used in determining the prices or amounts of the consideration in operations entered into with related parties (APA – Advance Unilateral and/or Multilateral Transfer Pricing Agreements or MAP – Mutual Agreeement Procedure) .
Advice and/or assistance in audit processes regarding transfer pricing. As well as, assistance in the resolution of controversies (Conclusive Agreements) and negotiations with local and international tax authorities for the resolution of MAPS (Mutal Agreement Procedures).
Maquiladora companies and calculation of the Safe Harbor.
Optimization of the structure of functions and risks through the application of economic models (value chain analysis and valuation of intangibles).
Bosques de Alisos 45-A 3er piso, Arcos Oriente, Col. Bosques de las lomas 05120, Cuajimalpa, Ciudad de México.