Transfer pricing rules for companies in the maquila industry have provided, since 2014, an option either to enter into negotiations for an advance pricing agreement (APA) or to elect to apply an administrative alternative known as the “safe harbor.”
For those maquila companies that decide to take the APA path, the Mexican tax administration (Servicio de Administración Tributaria—SAT) in November 2016 proposed a methodology for negotiating APAs under a program referred to as “fast track.” This methodology requires an agreement between the SAT and the U.S. government, as well as an active participation of the National Council of the Maquiladora and Export Manufacturing Industry (Consejo Nacional de la Industria Maquiladora y Manufacturera de Exportación (Index)).
Read a 2017 report (Spanish) [DPF 390 KB] prepared by the KPMG member firm in Mexico that outlines steps to follow to implement the fast track APA program.
For more information, contact a tax professional with KPMG's Global Transfer Pricing Services group in Mexico:
M. Teresa Quiñones | + 52 (55) 5246 8347 | firstname.lastname@example.org
© 2018 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. All rights reserved.
Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm.
The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.