Starting in the 2018 fiscal year, the SAT issued new rules to be able to make transfer pricing adjustments, which establish the form and documentation that will have to be available to make said adjustments.

In this sense, it is recommended that before the close of the fiscal year a review of the considerations established in intercompany operations be carried out and thus avoid making transfer price adjustments.

At FRALLA we can support our clients to review the compensation of intercompany operations before the close of the fiscal year.

The miscellaneous rules that establish the requirements for making adjustments are 3.9.1.1, 3.9.1.2, 3.9.1.3 and 3.9.1.4.

We remain at your disposal for any questions or clarifications regarding this publication.

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Mexico City

October 2023