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Consulting in Economics and Transfer Pricing


The global economy, the dynamic tax environment and the OECD’s initiative to prevent the base erosion and profit shifting (BEPS), have made essential for multinational enterprises to have a thorough analysis of the transfer prices within the value chain of its operational scheme. 

In recent years, tax authorities have specialized even more in this matter, which has translated into a greater number of audit processes focused on analyzing meticulously intercompany transactions and the consequent allocation of profits among entities of business groups. 

At Chevez Ruiz Zamarripa we are convinced that transfer pricing analyzes require an interdisciplinary vision in order to identify and structure commercial and financial relationships of the related parties integrating a business groups, beyond the mere compliance of legal and tax requirements. 

Our team is integrated by experts with an interdisciplinary profile that combines tax and legal expertise with the most advanced financial, economic and accounting analysis techniques, which together with a vast international experience and a deep knowledge of the particular characteristics of the Mexican business environment, we offer high added value to our clients, mainly multinational Groups. 

The services we offer include: 

  • Support and advisory in the resolution of transfer pricing disputes in all instances, including alternative defense mechanisms such as conclusive agreements with PRODECON and mutual agreement procedures (MAPs). 
  • Negotiation of unilateral, bilateral and multilateral advance pricing agreements. 
  • Transfer pricing diagnosis related with the value chain in the intercompany transactions carried out within members of a business group. 
  • Analysis of transfer prices to comply with the contemporaneous documentation requirements in accordance with the applicable legislations, including the three-tiered documentation standard: Master File, Local File and Country by Country Report. 
  • Transfer pricing advisory for the maquiladora industry. 
  • Valuation of companies, stock, intangibles, among others. 
  • Impairment of assets analysis. 
  • Advice on business restructurings based on transfer pricing. 
  • Economic, financial and market analyses related to trade remedies investigations, antitrust, as well as to any other variable that may affect an industry or product.