Transfer pricing in Mexico for subsidiaries
Transfer pricing study and returns for your Mexican subsidiary’s transactions with its parent company, from Monterrey.
Monterrey office
- Ave. Lázaro Cárdenas 304, Int. 101
Col. Residencial San Agustín, San Pedro, N.L. - +52 81 2317-48-80
- informacion@mayacontadores.com
- Monday to Friday: 9:00 – 18:00
Document transactions with your parent company before the SAT asks
Every time your Mexican subsidiary buys, sells, receives services or pays royalties to its parent company, the SAT expects the price to be the same that two independent companies would agree on. If it is not documented, deductions can be denied and tax differences assessed with penalties.
From Monterrey we prepare the transfer pricing study for each fiscal year and the related information returns, coordinated with what your parent company reports in its own country.
- Every fiscal yeartransactions are documented
- SAT and IRScoordinated criteria
- English and Spanishreports for your parent company
Updated: October 2026
Why your subsidiary needs transfer pricing
Mexican tax law requires companies that transact with related parties abroad to price those transactions at market value and keep supporting documentation. The SAT reviews these transactions closely, especially in subsidiaries of foreign groups.
A well-prepared study protects your deductions in Mexico and avoids contradictions with the documentation your parent company files in its country.
Typical transactions we document
Purchases and sales of goods with the parent company or affiliates.
Management, technical or administrative services between group companies.
Royalties for trademarks, technology or know-how.
Intercompany loans and financing.
Cost sharing and reimbursements within the group.
Does any of these sound like you?
Your first consultation is free, at our Monterrey office or by video call.
+52 81 2317-48-80 Write to usWhat the service includes
Transfer pricing documentation for subsidiaries of foreign groups operating in Mexico.
Transfer pricing study
Functional and economic analysis for each fiscal year.
Information returns
Related-party returns before the SAT.
Intercompany agreements
Review of contracts between group companies.
Planning
Pricing policies that can be defended before the authority.
How we prepare your transfer pricing
From the analysis of your transactions to the information returns.
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Transaction review
We identify all transactions with related parties and their contracts.
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Functional analysis
We review the functions, assets and risks of your subsidiary and the group.
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Economic analysis
We compare your prices or margins with those of independent companies.
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Documentation and returns
We deliver the study and file the information returns that apply.
Transfer pricing obligations
What a subsidiary with related-party transactions usually has to prepare. Thresholds and deadlines depend on your case.
US–Mexico tax treaty| Obligation | Authority | When |
|---|---|---|
Transfer pricing study |
SAT | Every fiscal yearkept as supporting documentation |
Related-party information return |
SAT | Annualwith the tax return calendar |
Local and master file, when they apply |
SAT | Annualdepending on the size of the group |
Intercompany agreements |
Your company | Before transactingkept up to date |
What we take care of
Deductions protected
Documentation ready before the SAT asks for it.
Consistency with the parent company
Criteria coordinated with what the group reports abroad.
Clear reports
Results explained in English or Spanish for management.
Does your subsidiary transact with its parent company?
Book a free consultation and we will review what documentation you need.
Frequently asked questions
Questions? Call us
+52 81 2317-48-80The prices agreed between companies of the same group. In Mexico they must be set as if the companies were independent and be supported with documentation.
If it has transactions with related parties abroad, it usually does. Some obligations depend on the size of the company; we review your case.
Yes. We work with the group’s advisors so the documentation in Mexico is consistent with what is filed abroad.
Yes. Maquiladoras have specific rules; our Querétaro office handles maquiladora transfer pricing.
Yes. We prepare reports and explanations in English.