Transfer Pricing Resources for Mexico Government Links Mexico's Tax Authority Homepage OECD Country Profile Other Resources Appendices 16 and 16-A to the Resolución Miscelánea Fiscal para 2008 (in Spanish language only) Mexico published transfer pricing financial reporting requirements, which require taxpayers to disclose additional transfer pricing and related information on their audit reports.  Included is a transfer pricing questionnaire to be completed by a Registered Public Accountant ("RPA").  This questionnaire is broken up into 11 sections, as follows: Section 1 - General Information—requires disclosure of the taxpayer’s main business activity, as well as whether the taxpayer owns, grants or licenses the intangible assets it uses in its business activity. Section 2 - Thin Capitalization—requires disclosure as to whether the taxpayer is complying with the Mexican thin capitalization rules. Section 3 - Transfer Pricing Study Documenting Cross-Border Intercompany Transactions—the RPA must indicate whether the taxpayer complied with the transfer pricing documentation requirements. Section 4 - Compliance with the Transfer Pricing Documentation Requirements—the RPA must indicate whether the transfer pricing documentation study related to the taxpayer’s cross-border intercompany transactions complies with the Mexican transfer pricing documentation rules under Fraction XII of Article 86 of Ley del Impuesto Sobre la Renta—LISR (the Mexican income tax law). Section 5 - Transfer Pricing Information Return of the Cross-Border Intercompany Transactions—requires disclosure of whether the taxpayer filed the transfer pricing information return and whether the amounts of the intercompany transactions were consistent with those listed in the transfer pricing study. Section 6 - Market Value of Domestic Intercompany Transactions—the RPA must indicate whether the transfer pricing documentation study with regards to domestic intercompany transactions complies with the Mexican transfer pricing documentation requirements. Section 7 - Back-to-Back Loans—requires disclosure of whether the taxpayer has complied with the Mexican rules with regards to back-to-back loans. Section 8 - Transfer Pricing Methodology—requires the RPA to indicate whether the transfer pricing documentation considered the application of the Comparable Uncontrolled Price Method as the preferred methodology of analysis. Section 9 - Use of Segmented Financial Information in the Mexican Transfer Pricing Study—requires the RPA to indicate whether it audited the segmented financial information. Section 10 - Maquiladoras—requires the RPA to disclose whether the taxpayer operated under a maquiladora program as well the transfer pricing methodology used for documentation purposes. Section 11 - Single Rate Business Tax—requires the RPA to indicate whether it audited the taxpayer’s developed transfer pricing documentation to support the intercompany transactions conducted for purposes of the Impuesto Empresarial a Tasa Única (a single rate business tax) Published on February 20 and March 2, 2009 Peer Review of Mexico's Transfer Pricing Legislation and Practices Provides an overview of the application of the arm’s length principle in Mexico, transfer pricing and comparability issues, transfer pricing compliance practices, documentation and related penalties, maquiladoras, APAs, and mutual agreement procedures. Published January 2005 DEVELOPED BY [click here]