Your specialized transfer pricing advisor
Your specialized transfer pricing advisor
Specialized Firm
QCG Transfer Pricing is a specialized practice dedicated to providing holistic, strategic solutions that turn your transfer pricing structure into a true value driver. Our solutions go beyond compliance. From planning optimal value chain structures, benchmarking and all compliance documentation to controversy support and defense, we can assist you in every step of your transfer pricing analysis.
Our goal is to transform you transfer pricing strategy into a true value driver for your organization.
Technical excellence
Every solution we deliver is built on technical precision, guaranteeing optimal results, minimizing risk and maximizing benefits in every transaction.
Innovation at our core
We integrate cutting-edge tax technology to streamline compliance and drive efficiency. Our proprietary Transfer Pricing Diligent® platform, developed by transfer pricing experts, enhances documentation accuracy and simplifies complex analyses. We also leverage econometric models and automation to optimize the analysis process.
Multidisciplinary practice
Our team of accountants, economists, finance professionals, and legal experts delivers industry-specific solutions tailored to your business. This integrated approach ensures comprehensive, innovative, and defensible transfer pricing strategies to satisfy the specific needs of every client.
Publications
Business Purpose, Economic Substance, and Transfer Pricing: The New Trilogy of Mexican Tax Audits
In multinational groups, the question comes up often: why is a related-party transaction challenged when there is a contract, a CFDI electronic invoice, documented payment, and a transfer pricing study?
The answer is direct: tax audits no longer look only at form. Today, Mexico’s tax authority (the SAT) examines whether the transaction had a business purpose, whether it had economic substance, and whether its consideration was set in line with the arm’s length principle. The analysis is no longer documentary — it is structural.
The Basics of Transfer Pricing Risk in the U.S. and the Consequences of Non-Compliance
For multinational enterprises (MNEs), navigating the global tax landscape is increasingly complex. Transfer pricing—the practice of setting prices for goods, services, and intangibles exchanged between related parties within a multinational group—plays a central role in that challenge. Failure to comply with U.S. transfer pricing rules can expose multinational groups to
Key Developments in Transfer Pricing in Mexico
October–November 2025 During the last quarter, Mexico saw significant developments that redraw the enforcement landscape for multinational groups. The SAT published new risk criteria for 2026 audits, the Supreme Court resolved an emblematic case with direct implications for transfer pricing, and the OECD recognized the country’s capacity in APAs and
25 years
Of continuous transfer pricing experience
15,000 +
Successfully delivered engagements
10 years
Of specialized industry forums
7 times
Nominated as Best Transfer Pricing firm by ITR
Schedule a consultation
Schedule a meeting with us to discuss international taxation and transfer pricing issues. Call us or send us your information.