Asked about Mexico transfer pricing rules, documentation requirements, or precios de transferencia compliance.
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This Guide is general tax/accounting reference material for AI-assisted workflows. It has not been reviewed for your personal facts, documents, elections, deadlines, residency, filing status, or local procedures. Do not rely on it to file, pay, amend, or take a tax position without review by a qualified professional in the relevant jurisdiction.
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Local File income threshold (cumulative income)
> MXN ~1,940 million (2025; indexed annually)Articles 76-A, 179-184, Income Tax Law (Ley del ISR -- LISR)
Master File income threshold
Same as Local File (> MXN ~1,940 million; indexed annually)Articles 76-A, 179-184, Income Tax Law (Ley del ISR -- LISR)
CbCR consolidated group revenue threshold (original)
> MXN 12 billionArticles 76-A, Income Tax Law (Ley del ISR -- LISR)
CbCR consolidated group revenue threshold (indexed)
~MXN 16.59 billion (per indexed thresholds)Articles 76-A, Income Tax Law (Ley del ISR -- LISR)
CbCR EUR equivalent threshold (approximate)
approx. EUR 750 millionArticles 76-A, Income Tax Law (Ley del ISR -- LISR)
Local File filing deadline
May 15 of the following fiscal yearArticles 76-A, Income Tax Law (Ley del ISR -- LISR)
Master File filing deadline
December 31 of the following fiscal yearArticles 76-A, Income Tax Law (Ley del ISR -- LISR)
CbCR filing deadline
December 31 of the following fiscal yearArticles 76-A, Income Tax Law (Ley del ISR -- LISR)
TP Report preparation deadline
By time of annual tax return filing (March 31 for legal entities)Article 76, Income Tax Law (Ley del ISR -- LISR)
Annual tax return (Declaración Anual) deadline for legal entities
March 31 of the following fiscal yearFiscal Code (CFF); Income Tax Law (Ley del ISR -- LISR)
Maquiladora informative return deadline
June of the following fiscal yearArticle 182, Income Tax Law (Ley del ISR -- LISR)
First Local File filing deadline for FY2025
May 15, 2026Articles 76-A, Income Tax Law (Ley del ISR -- LISR)
Late/incomplete TP informative return documentation — penalty range (lower bound)
MXN 199,630 (indexed annually)Fiscal Code (CFF)
Late/incomplete TP informative return documentation — penalty range (upper bound)
MXN 284,220 (indexed annually)Fiscal Code (CFF)
SAT TP adjustment — tax omission surcharge rate (lower bound)
55% of historical omitted taxesFiscal Code (CFF)
SAT TP adjustment — tax omission surcharge rate (upper bound)
75% of historical omitted taxesFiscal Code (CFF)
Late payment surcharge (recargos)
1.47% monthly on unpaid taxFiscal Code (CFF)
APA governing legislation
Article 34-A, Fiscal Code (CFF)Article 34-A, Fiscal Code (CFF)
APA maximum duration
Up to 5 years (year of request + 1 prior year + up to 3 forward years)Article 34-A, Fiscal Code (CFF)
APA application fee
No formal feeArticle 34-A, Fiscal Code (CFF)
Maquiladora APA — eliminated from
FY2022 reform; no longer available from FY2025Article 182, Income Tax Law (Ley del ISR -- LISR)
Safe harbour taxable profit — minimum based on total costs/expenses
6.5% of total costs/expenses (including foreign-sourced)Article 182, Income Tax Law (Ley del ISR -- LISR)
Safe harbour taxable profit — minimum based on total assets
6.9% of total assets (including foreign-owned assets)Article 182, Income Tax Law (Ley del ISR -- LISR)
Safe harbour taxable profit — determination rule
GREATER of: 6.5% of total costs/expenses OR 6.9% of total assetsArticle 182, Income Tax Law (Ley del ISR -- LISR)
Consequence of non-compliance with safe harbour
Foreign principal deemed to have a Permanent Establishment in MexicoArticle 182, Income Tax Law (Ley del ISR -- LISR)
Statistical range methodology
Interquartile range; adjustment to median if result is outside rangeArticle 180, Income Tax Law (Ley del ISR -- LISR)
Primary TP legislation articles
Articles 76, 76-A, 179-184, Income Tax Law (Ley del ISR -- LISR); Fiscal Code (CFF) Art. 34-A (APA)Articles 76, 76-A, 179-184, Income Tax Law (Ley del ISR -- LISR); Article 34-A, Fiscal Code (CFF)
TP Report filing method
Not filed; maintained and available on SAT requestArticle 76, Income Tax Law (Ley del ISR -- LISR)
Local File filing method
Electronic submission to SATArticles 76-A, Income Tax Law (Ley del ISR -- LISR)
Master File filing method
Electronic submission to SATArticles 76-A, Income Tax Law (Ley del ISR -- LISR)
CbCR filing method
Electronic submission to SATArticles 76-A, Income Tax Law (Ley del ISR -- LISR)
Local File language requirement
SpanishArticles 76-A, Income Tax Law (Ley del ISR -- LISR)
Master File language requirement
Spanish or EnglishArticles 76-A, Income Tax Law (Ley del ISR -- LISR)
Section 1 -- Quick Reference
| Field | Value |
|---|---|
| Country | Mexico (United Mexican States) |
| Tax authority | Servicio de Administración Tributaria (SAT) |
| Key TP legislation | Articles 76, 76-A, 179-184, Income Tax Law (Ley del ISR -- LISR); Fiscal Code (CFF) Art. 34-A (APA) |
| OECD member? | Yes |
| BEPS signatory? | Yes |
| Currency | MXN |
| Documentation language | Spanish (Local File); Master File in Spanish or English |
| TP documentation types | Four types: TP Report, Local File, Master File, CbCR |
| Skill version | 1.0 |
2.1 TP Report (Estudio de Precios de Transferencia)
| Item | Detail |
|---|---|
| Required? | Yes, for taxpayers with related-party transactions (general obligation under Art. 76 LISR) |
| Threshold | All entities with controlled transactions must have TP study available |
| Content | Functions/assets/risks, method selection, comparables, arm's length analysis |
| Language | Spanish |
| Filing | Not filed; maintained and available on SAT request |
2.2 Local File (Archivo Local)
| Item | Detail |
|---|---|
| Required? | Yes, for entities with cumulative income > MXN ~1,940 million (2025; indexed annually) |
| Format | Per BEPS Action 13 / OECD standards with Mexico-specific content |
| Language | Spanish |
| Filing deadline | May 15 of the following fiscal year |
| Filing method | Electronic submission to SAT |
2.3 Master File (Archivo Maestro)
| Item | Detail |
|---|---|
| Required? | Yes, for entities meeting the income threshold (same as Local File) |
| Format | OECD Annex I to Chapter V |
| Language | Spanish or English |
| Filing deadline | December 31 of the following fiscal year |
| Filing method | Electronic submission |
2.4 Country-by-Country Report (CbCR)
| Item | Detail |
|---|---|
| Threshold | Consolidated group revenue > MXN 12 billion (approx. EUR 750m; updated: ~MXN 16.59 billion per indexed thresholds) |
| Filing deadline | December 31 of the following fiscal year |
| Content | Per OECD Annex III |
| Filing method | Electronic |
3.2 Accepted Methods (Article 180 LISR) (Article 180 LISR)
| Method | Accepted |
|---|---|
| Comparable Uncontrolled Price (CUP) | Yes |
| Resale Price Method (RPM) | Yes |
| Cost Plus Method (CPM) | Yes |
| Transactional Net Margin Method (TNMM) | Yes |
| Profit Split Method (PSM) | Yes |
| Residual Profit Split | Yes |
Section 4 -- Filing Obligations
| Obligation | Detail |
|---|---|
| TP Report | Maintain; available on SAT audit request |
| Local File | Annual electronic filing (May 15) |
| Master File | Annual electronic filing (December 31) |
| CbCR | Annual electronic filing (December 31) |
| Annual tax return (Declaración Anual) | Includes informative obligations on related-party transactions |
| Informative multiple return | Related-party transaction information in annual return |
Section 5 -- Deadlines
| Item | Deadline |
|---|---|
| Local File | May 15 of the following fiscal year |
| Master File | December 31 of the following fiscal year |
| CbCR | December 31 of the following fiscal year |
| TP Report preparation | By time of annual tax return filing (March 31 for legal entities) |
| Annual tax return | March 31 of the following fiscal year |
| Maquiladora informative return | June of the following fiscal year |
Section 6 -- Penalties
| Offence | Penalty |
|---|---|
| Late/incomplete TP informative return documentation | MXN 199,630 -- MXN 284,220 (indexed annually) |
| Failure to file Local File / Master File | Similar administrative fines |
| SAT TP adjustment -- tax omission | 55-75% of historical omitted taxes |
| Late payment surcharge | 1.47% monthly on unpaid tax |
| Inflation adjustment | Tax debt indexed for inflation |
| Non-compliance with maquiladora safe harbor | Deemed permanent establishment of foreign principal |
Section 7 -- Advance Pricing Agreements (APA)
| Item | Detail |
|---|---|
| Availability | Yes (general APA under Art. 34-A CFF) |
| Types | Unilateral (primarily); bilateral available |
| Governing legislation | Article 34-A, Fiscal Code (CFF) |
| Application | To SAT with proposed methodology |
| Duration | Up to 5 years (year of request + 1 prior + up to 3 forward) |
| Fees | No formal fee |
| Processing time | Variable; historically lengthy |
| Maquiladora APA | ELIMINATED from 2022 reform; no longer available from FY2025 |
8.1 Maquiladora Safe Harbour (Article 182 LISR) (Article 182 LISR)
| Item | Detail |
|---|---|
| Applicable to | Maquiladora companies operating under Art. 181 LISR |
| Calculation | Taxable profit = GREATER of: 6.5% of total costs/expenses (including foreign-sourced) OR 6.9% of total assets (including foreign-owned assets) |
| Mandatory from 2025 | Only mechanism available (APA option eliminated) |
| Consequence of non-compliance | Foreign principal deemed to have a Permanent Establishment in Mexico |
| Annual informative return | Required in June of following year |
Section 9 -- Recent Developments
| Date | Development |
|---|---|
| 2025 | Maquiladora APA option expired (last APAs covered 2021-2024); safe harbour now mandatory |
| 2024 | Updated indexed thresholds for documentation obligations |
| 2022 | Tax reform eliminated maquiladora APA from Article 182 LISR |
| 2025 | Pillar Two under discussion; no legislation enacted yet |
| Ongoing | SAT increasing TP audit activity, especially on maquiladoras and digital services |
| Ongoing | Focus on substance requirements for intercompany transactions |
| May 2026 | First Local File filing deadline for FY2025 (May 15, 2026) |
Section 10 -- Interaction with Other Skills
| Related skill | Interaction |
|---|---|
| mexico-corporate-tax (ISR) | TP adjustments directly affect income tax (ISR) base |
| mexico-bookkeeping | TP documentation relies on Mexican accounting standards (NIF) |
| mexico-vat (IVA) | TP adjustments may affect customs valuation and IVA |
| Maquiladora regime | Safe harbour is the sole TP mechanism for maquiladoras from 2025 |
| Customs valuation | Related-party import pricing must be consistent with TP positions |
| CbCR | SAT uses CbCR for risk-based audit selection |
| Double tax treaties | Mexico's DTA network provides MAP for TP disputes |
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