Following the resolution issued by the Second Tax and Customs Court of the Metropolitan Region in deciding the claim filed under the general claims procedure
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.
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
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