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In this episode, our partners José Carlos Silva and Francisco Gutiérrez-Zamora provide us with relevant information about Nearshoring, approaching the topic from a perspective focused on Social Security.

The firm's tax and foreign trade legal areas will be pleased to provide more details on this matter and its effects.

En este episodio, Gloria Niembro, socia del área de Propiedad Intelectual, se une a Mariel Velázquez, consultora de proyectos en derechos humanos, igualdad de género y sustentabilidad, ...

On January 27, 2016, 31 Countries1 (among them Mexico) signed the Multilateral Competent Authority Agreement for automatic exchange of Country-by-Country reports (the "Agreement") to be received from their taxpayers as part of the implementation of Action 13 of the Base Erosion and Profit Shifting Action Plan issued by the Organisation for Economic Co-operation and Development.

This instrument was negotiated among more than 100 countries and will bring changes on more than 2000 tax treaties around the world.

On August 4, 2023, the Federal Executive published in the Official Gazette of the Federation the "Decree enacting the Protocol Amending the Agreement dated July 9, 2008, between the United Mexican States...

After two years of work, on October 5, 2015 the OECD presented the final package of the 15-action Base Erosion and Profit Shifting (BEPS) Action Plan...

In Mexico, a company with a local presence that is currently undergoing, or may in the future undergo, a tax review for FY 2020 of its transfer pricing policies (or other international tax matters) that may give rise to a case...

What if the future of audit quality depended less on checklists and more on integration?

As an exception to the rules governing deductions in our Income Tax Law, administrative rules allow taxpayers to increase their deductions as a result of transfer pricing adjustments...

When a foreign executive extends their stay in Mexico to lead operations, negotiate terms, or direct personnel, they may inadvertently create permanent establishment exposure for their company—regardless of how many days they've spent in the country. The real risk isn't crossing the 183-day threshold; it's about where decisions are made, what authority is exercised, and whether the foreign enterprise is effectively conducting business through a fixed place or dependent agent in Mexico.

In cross-border structures, contracts are often seen as the ultimate safety net. If the agreement is well drafted, properly signed, and aligned with internal policies...

Article 181 of the Income Tax Law ("ITL") establishes the requirements that must be met in order to consider that taxpayers are performing maquila operations eligible for the transfer pricing safe harbor.

La OCDE informó que el 23 de mayo de 2016, aprobó las modificaciones a las Guías sobre Precios de Transferencia a Empresas Multinacionales y Administraciones Fiscales que aparecen en el informe de 2015 sobre las acciones BEPS 8, 9 10 y 13 .

On May 11, 2019, the Second Section of the Superior Chamber of the Federal Tax Court issued two isolated rulings in relation

For the last four years, the Mexican government has passed a number of strategic reforms designed to make the economic environment in Mexico more appealing and competitive for foreign and domestic investors.