SeemaSphere
Your gateway to global financial intelligence — featuring key developments in transfer pricing, tax law, and regulatory guidance.
Expore all reads
Documentation Structure per the 2020 Decree
Penalty protection for transfer pricing adjustments requires that documentation exactly follows the structure outlined in the 2020 Ministerial Decree, mirroring the OECD/BEPS framework. The Master File may be in English, but the Local File is required in Italian. Both must be digitally signed and provided upon request.
Guidance on Statistical Methods & Range
Recent guidance by the Italian Revenue Agency---through Circulars 15/2021 and 16/2022---details the use of statistical ranges (including the application of interquartile range), the treatment of loss-making comparables, and how to set points within an arm's length range, closely tracking OECD positions.
Integration with Customs Valuation
Regulations and joint guidelines between Customs and Revenue authorities reinforce the requirement to reconcile year-end transfer pricing adjustments with customs valuation, affecting both direct and indirect tax positions if intercompany product prices change after year-end.
Mandatory Public Country-by-Country Reporting
Multinationals headquartered in Italy with consolidated revenues above €750 million must file a CbC Report. EU legislation effective 2024/25 now also requires portions of these reports be made public, increasing transparency.
Shorter Filing Window & Electronic Documentation
From 2025, Italian companies must file their tax returns within nine months of the fiscal year-end rather than the previous eleven. For December year-end companies, the new deadline is September 30. To obtain penalty protection for transfer pricing documentation, firms must prepare and digitally sign their Local and Master Files ahead of the tax return deadline. In specific circumstances, authorities permit a ninety-day extension if files are not ready.
Tougher Penalties without Documentation
Effective September 1, 2024, failing to prepare compliant transfer pricing documentation exposes taxpayers to a 70% penalty on any additional taxes assessed. By contrast, full documentation---meeting strict format and timing standards---secures protection from such penalties.
Alignment with OECD Transfer Pricing Guidelines
Mexico's transfer pricing regime is based on OECD Guidance and Articles 179--180 of the Mexican Income Tax Law (Ley del ISR). The arm's length principle applies to cross-border and some domestic transactions, referencing the 2022 OECD Guidelines for method selection and compliance.
.jpg&w=3840&q=75)
Latest Litigation and Audit Trends
Recent SAT enforcement focuses on restructurings, hard-to-value intangibles, and intercompany financing. Courts require robust evidence and full documentation, frequently citing the OECD and Mexican law in rulings.
.jpg&w=3840&q=75)
Mandatory Master File, Local File, and Informative Return
Multinational groups and domestic taxpayers must file the annual Informative Return on Related Parties (Annex 9 of DIEMSE), with Master and Local File documentation due by the tax return deadline (generally March 31 of the following year). These must meet the extensive SAT and OECD content requirements.
Country-by-Country Reporting Obligations
MNEs with consolidated revenues of at least MXN$12 billion must file a Country-by-Country (CbC) report within 12 months of fiscal year end. Mexico has adopted the OECD CbC framework, with enforcement led by SAT.
Showing -59 to -50 of 114 articles
