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) [PDF 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 | email@example.com
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