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Introduction
This article provides a high-level overview of some of the common business models used by local entities that are engaged in the distribution, sale and marketing of their group s products and analyses the potential transfer pricing ramifications thereof.
The transfer pricing analysis included in this article is predominantly based on Circular 11/2018 (Determination of the appropriate transfer pricing method for activity related to distribution, marketing and sales of a multinational group within the local market),(1) published by the Israeli Tax Authority (ITA). Circular 11/2018 implements the Organisation for Economic Cooperation and Development (OECD) Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017 (OECD guidelines).
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Just in time for the holidays, the OECD has published
detailed guidance about the impact of the COVID-19 pandemic on
transfer pricing. The guidance has useful information for taxpayers
and tax administrations alike. It contains general advice on the
application of basic transfer pricing principles during the
pandemic, as well as specific advice on four issues: (i)
comparability analyses, (ii) allocating losses, (iii)
government-assistance programs, and (iv) advance pricing
arrangements ( APAs ). The OECD guidance is broadly
consistent with comments we made in
a prior post about the impact of the pandemic on transfer
Mexico s Reportable Transactions Rules in Effect January 1 Monday, December 21, 2020
Beginning January 1, 2021, Mexico’s reportable transaction rules require either a taxpayer or a tax advisor to report to the Mexican tax authorities any transactions that are designed, marketed, organized, implemented or administered to provide a tax benefit to the taxpayer.
What is a Reportable Transaction?
A reportable transaction is considered to be any transaction that generates or may generate, directly or indirectly, a tax benefit in Mexico and has any of the following characteristics:
Prevents foreign authorities from exchanging tax or financial information with Mexican tax authorities.
Avoids the application of the preferential tax regime (“REFIPRE”) or of transparent tax entities and foreign instruments.