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Study regarding the Transfer Pricing Reforms 2022

Study regarding the Transfer Pricing Reforms 2022

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Fernando F. Galindo Cantú, Partner of the firms Galindo Treviño Asociados and G&T Business Consultants, issued a technical analysis regarding the reforms applicable to transfer pricing 2022 in his website the “Fiscalía.”

Transfer Pricing Modifications

Unlike previous years, the new tax reform contains changes in Articles of the Income Tax Law and the CFF (Código Fiscal de la Federación – Federal Fiscal Code) referring to the so-called Transfer Pricing regime. Therefore, among the issues addressed by the reform can be found:

  1. Adjustments to the obligatory nature of the “Arm’s Length” paradigm.
  2. Adjustments to the content of the Set of Supporting Documentation.
  3. Set of Supporting Documentation for National Operations.
  4. Informative Declaration of National Operations.
  5. Change of Deadlines of informative and Expansion of spectrum of obligatory nature of “Master File and Local Report.”
  6. “Contemporaneous” Comparability Analysis and elimination of “Multiple Years.”
  7. Legality theme polishing regarding the Interquartile Method.
  8. Maquiladoras issue.
  9. Increase in Fines.
  10. Changes in Procedures during Audits.

Galindo proceeded to issue his analysis providing a set of comments on the subject, except for the maquiladoras, since these companies are “a separate species” which have a very particular field of application and require their own separate analysis regarding the rest of the taxpayers of the non-maquiladora sector.

Source: Fiscalia 01/12/21

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