In the Mexican government’s 2016 federal budget, presented 8 September 2015, there are proposals that would expand the transfer pricing disclosure requirements. In particular, a measure would require certain taxpayers (as identified pursuant to Article 32-H) that engage in transactions with related parties, to submit to the tax authorities certain country-by-country (CbC) information about the taxation of their business transactions.
Master file: The information to be submitted under “master information returns” of the multinational enterprises (MNE) group would contain the following information with regards to the MNE group:
Local file: The information to be submitted under the “local information return” for related parties would include:
The country-by-country (CbC) information return of the MNE group members would need to include the following information:
The CbC information return would be required to be submitted by taxpayers in any of the following situations:
The Mexican tax authorities would establish general rules for submitting the transfer pricing and CbC information returns, and might also request additional information. For instance, the tax authorities might request a CbC information return be filed with respect to: (1) Mexican taxpayers that are subsidiaries of a foreign taxpayer; and (2) foreign residents with a permanent establishment in Mexico in situation when the tax authorities are not able to obtain the information using a mechanism for the exchange of information between tax authorities. Taxpayer would then have 120 business days from the date when the notification is provided in order to submit the CbC information return.
Read a September 2015 report (Spanish) prepared by the KPMG member firm in Mexico: Propuestas de reforma derivadas del plan de acción de la OCDE referente a BEPS
For more information, contact a tax professional in Mexico with KPMG’s Global Transfer Pricing Services group:
Teresa Quiñones | + 1 (52) 555 246-8347 | email@example.com
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