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
The “Master Tax Audit Plan 2025” presented by the SAT prioritizes three key areas: taxpayer assistance, support for compliant taxpayers, and tax enforcement against evasion and smuggling. To achieve this, the SAT has increased the use of technological tools and artificial intelligence in audits, focusing primarily on compliance with transfer pricing obligations.
In December 2024, the Internal Revenue Service (IRS) announced that it will adopt the OECD’s Simplified and Standardized Approach (SSA) as a transfer pricing method for routine distribution and marketing transactions. This development could reshape how companies handle tax compliance in these operations.
In recent years, both national and international tax authorities have significantly intensified audits related to transfer pricing.