OECD Recognition of Mexico for Tax Certainty for Large Taxpayers

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Mexico's Tax Administration Service (SAT) has received significant recognition from the Organization for Economic Co-operation and Development (OECD) on Tax Certainty Day 2025, highlighting its efficient management in providing tax certainty to large taxpayers.

The Mexican tax authority was honored with two key distinctions:

First Place in "Age of Inventory": This award recognizes the SAT for maintaining an up-to-date inventory in Mutual Agreement Procedures (MAPs), achieving the timely resolution of cases in coordination with countries that are signatories to double taxation treaties. The efficient completion of these procedures, resulting from tax audits, ensures the correct determination of Income Tax (ISR) for multinational companies with operations in Mexico.

Second Place as "Most Improved Jurisdiction in Transfer Pricing Agreements" (APA Most Improved Jurisdiction): This award highlights the effectiveness of the Mexican Tax Administration Service (SAT) in the early resolution of Transfer Pricing Agreements (APAs). The swift handling of APAs prevents future disputes and ensures, prior to an audit, the correct payment of income tax by Mexican companies that are part of multinational corporate groups.

These achievements are a direct result of Mexico's commitment to Action 14 of the G20 and OECD Initiative to Combat Base Erosion and Profit Shifting (BEPS), which focuses on improving the effectiveness of tax dispute resolution mechanisms.

The SAT has strengthened legal certainty by signing more than 120 agreements in the last seven years, building upon the 60 existing double taxation treaties. This legal framework and clear institutional strategy have incentivized foreign investment in the country, offering multinational business groups a high degree of advance certainty regarding compliance with their tax obligations.

Tax certainty is a priority for the nation, promoting transparent regulations, increasing the efficiency of tax authorities, and fostering taxpayer confidence, thus reaffirming the SAT's commitment to the proper application of laws and international treaties.

Source:

https://www.gob.mx/sat/prensa/otorga-ocde-reconocimiento-a-mexico-por-dar-certidumbre-fiscal-a-grandes-contribuyentes-058-2025?idiom=es

With reference to the OECD event page:

https://www.oecd.org/en/events/2025/10/oecd-tax-certainty-day-2025.html#category6.