Transfer Pricing

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In today’s increasingly regulated tax environment, transactions between national or foreign related parties cannot be left to chance.

At ICM, we design, evaluate, and properly document transfer pricing studies, ensuring full compliance with the Mexican Income Tax Law and minimizing risks during tax audits.

Our goal: to ensure your cross-border or intra-group transactions are technically sound, legally defensible, and strategically optimized.

We provide specialized advisory for national and international companies engaging in related-party transactions.
We comply with Mexican regulations and international documentation standards.

✔ Solid experience in fiscally complex sectors
✔ Up-to-date studies aligned with current regulations
✔ Strategic support in Safe Harbor and APA processes
✔ Technical + fiscal + business insight = full compliance
✔ Direct access to experts — no intermediaries

Global tax planning for companies doing business beyond Mexico.
We guide our clients in the proper application of international treaties, foreign investment structures, and cross-border operations.

Includes:

• Advisory on double taxation treaties
• Strategies to minimize tax burden in international operations
• Tax planning for foreign investors in Mexico or Mexicans abroad
• Efficient structures with full documentation for authorities
• Diagnostics to identify tax-saving opportunities in global setups

• Full study development in compliance with Mexican Income Tax Law
• Functional, economic, and comparability analyses
• Supporting documentation for intra-group transactions
• Application of the most appropriate valuation methods

• Feasibility analysis for simplified regimes
• Technical determination of law-compliant profit margins
• Strategic support to justify benefits and avoid tax adjustments

• Technical and fiscal support to accurately complete the foreign related-party annex
• Validation of financial data and supporting documentation 
• Consistency checks with your transfer pricing study and other tax reports

• Operate with subsidiaries, affiliates, or group entities
• Buy from or sell to related foreign companies
• Are under audit or require strong documentation defenses
• Must comply with OECD, BEPS, or international tax standards
• Seek long-term stability and tax certainty
         

A tax expert will review your case and guide you with a personalized, obligation-free consultation

Let’s talk on WhatsApp. One of our senior partners in international taxation will assist you directly — no intermediaries.

Take the first step toward stronger operations.
Book your appointment now and receive guidance from our expert team.