The Mexican government recently passed a new regulation to permitting the Mexican Tax Authorities to perform on-site visits to carry out their own functional analysis as a part of the Advanced Pricing Agreement (APA) process. Rule 2.12.8 published on July 14, 2016 states that if the Mexican Tax Authorities consider the information provided by the taxpayer to be insufficient, they may perform a site visit to obtain and verify information regarding assets, functions, and risks of the Mexican taxpayer requesting an APA in order to validate the selection of method as well as the comparable companies.
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