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
On May 26, 2025, Mexico’s Tax Administration Service (SAT) announced a 367% increase in tax revenue from transfer pricing audits in the period from 2019
On January 29, 2023, the Tax Administration Service (SAT) announced its 2023 Master Plan for Auditing and Collection. While there was no tax reform in
It has become very common to consider that market prices, and even the application of “fair” asset valuation methods, are widely accepted and sufficient to