Transfer pricing adjustment: New provisions in the Miscellaneous Tax Resolution for 2017.


Dear clients and friends:


 

On December 23rd, 2016, the issuance of the Miscellaneous Tax Resolution for 2017 (hereinafter “Miscellaneous Tax”) was published in the Official Gazette of the Federation, which entered into force on January 1st, 2017 and will be effective until December 31st, 2017. In the Miscellaneous Tax, a new section called “Transfer pricing adjustments” is highlighted.

 

Transfer pricing adjustments shall be defined as: “any changes in prices, amounts of consideration or profit margins corresponding to the operations carried out by the taxpayer with its related parties, to be carried out to consider that the cumulative income or authorized deductions derived from such transactions were determined by considering the prices or amounts of consideration that they had used with or between independent parties in comparable transactions, even when no cash or other material resources were delivered between the parties.”.

 

This section establishes the rules for making transfer pricing adjustments that result in increasing or decreasing, as the case may be, the price, amount of the consideration or the margin of the transaction entered into between related parties.

 

It also indicates the requirements to be met by taxpayers who make a transfer pricing adjustment in order to increase their deductions.

 

If you require more information about the content of this provision we invite you to  contact us.

 

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