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
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
- 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
- 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
- Valuation of companies, stock, intangibles, among
- Impairment of assets analysis.
- Advice on business restructurings based on transfer
- 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.