Companies in Mexico that have transactions with related parties in Mexico and abroad are required to carry out their intercompany transactions in compliance with the transfer pricing regulations, therefore, they must have the documentation that demonstrates that said transactions were agreed upon in accordance with the arm’s length principle in accordance with the provisions of articles 76 sections IX and XII, 76-A, 179 and 180 of the Income Tax Law (ITL). 

Thus, if the company has income in the immediately preceding fiscal year equal to or greater than $13,000,000 pesos, or $3,000,000 in the case of professional services, it will be required to prepare a transfer pricing study in which compliance with the Arm's Length principle is determined and to prepare an informative return (Annex 9 of the DIM). 

On the other hand, if your company has income in the immediately preceding fiscal year equal to or greater than $1,016,759,000 pesos, or is a permanent establishment in Mexico, as well as if it is a related party of an entity in Mexico that is required to submit the Statutory Tax Report (Dictamen Fiscal), you will be required to submit to the Tax Administration Service (SAT) the annual informative returns for related parties, which consist of the Master File, when you are part of a Multinational Group, and the Local File, for all taxpayers regardless of whether they are part of a Multinational Group. 

The deadline for filing transfer pricing returns is May 15 of the fiscal year immediately following the end of the year, although remember that, in case you require an adjustment in transfer pricing, this must be submitted in the annual return with a deadline of March 31st.

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