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Growth of advanced pricing agreements in Mexico

The TP landscape in Mexico has developed in a positive way Over the last 25 years, the transfer pricing (TP) landscape in Mexico has developed in a positive way. Information provided by the Instituto Nacional de Transparencia, Acceso a la Información y Protección de Datos Personales (INAI) shows that the Mexican Tax Authority ( Servicio de Administración Tributaria, SAT) has significantly increased its advanced pricing agreement (APA) cases within the last decade and this is likely to continue to grow in the coming years. This is a consequence of the current environment, because businesses have been evolving making those more complex, competitive and challenging, due to new technologies, but also due to the existence of new competitors, ways to conduct operations, value added and consumers’ preferences.

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