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
QCG Transfer Pricing has been ranked as a Tier 1 firm in Mexico by ITR World Tax for 2025, reaffirming our commitment to technical excellence and client trust.
When dealing with financial transactions between related parties, particularly in the case of intercompany loans, a key issue is determining the appropriate interest rate to
Summary This article proposes a reinterpretation of the arm’s length principle in transfer pricing, grounded in the economic efficiency of contractual structures. Traditionally, only transactions