On 28th March, 2017 the SAT released its long-awaited Announcement on Special Tax Investigations and Adjustments (Announcement 6). Announcement 6 integrates some of the OECD BEPS work, particularly those on intangibles, into domestic regulations. It also consolidates previous regulations on self-adjustments and outbound payments, and writes into regulation some of the existing practices adopted for transfer pricing audits. Announcement 6 also revised and clarified the relevant contents of the transfer pricing audits and mutual agreement procedures and would be effective from 1st May, 2017.
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