Recent developments within the Mexican Tax Administration Services (SAT) demonstrate an increased focus on auditing supply chain restructurings. This is in line with international trends in transfer pricing, for example the report on business restructurings that was issued by the OECD and incorporated into the OECD transfer pricing guidelines. The SAT’s General Administrator for Large Taxpayers has expressed his intention to challenge companies that have undertaken restructurings to reduce their tax liabilities in Mexico while maintaining their business functions and customers in Mexico. This would include maquila conversions. This audit program initiative is intended to challenge companies that have been engaged in what the SAT considers “aggressive tax planning,” involving profit shifting.
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