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Details of new transfer pricing disclosure requirements in Mexico

March 11, 2009

Instructions for completion, guidance formats, and questionnaires related to the review by the registered external auditor (external CPA), and the electronic filing, of the financial audit report for 2008 were published in Mexico’s Federal Register at the end of February. The most relevant (and controversial) aspects of such instructions, formats, and questionnaires have to do with transfer pricing.

The 2008 financial audit reports for Mexican taxpayers that conduct transactions with related parties (either domestic or foreign) must include detailed information regarding such transactions. Three attachments to the reports are now required in order to disclose such information, as follows:

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