The corporate tax rate is 30%.
The OECD TPG are specifically referenced in the Mexican legislation, and are used for guidance and interpretation in transfer pricing-related issues.
Transfer pricing rules are included in Articles 86 (Sections XII, XIII and XV), 215, 216 and 216-BIS of the MITL. These rules require taxpayers to produce and maintain documentation demonstrating that gross receipts and allowable deductions for each fiscal year arising from inter-company transactions are consistent with the amounts that would have resulted had these transactions taken place with unrelated parties under similar conditions. Moreover, documentation of arm’s-length nature of inter-company transactions should be completed on a transactional basis. The transfer pricing documentation requirements are regulated by Article 86 Section XII of the MITL.
All inter-company transactions between related parties, including domestic and foreign-related parties, must be reflected at arm’s-length prices for income tax purposes, including transfers of tangible and intangible property, services, rental or licensing of assets, loans and transfers of shares (whether publicly traded or not), and applies to both domestic and foreign transactions entered into by individual and corporate taxpayers.
Transfer Pricing Case Law