SAT’s Position on Amount B: Participation in the OECD Tax and Development Days

Within the framework of the 2026 edition of the OECD Tax and Development Days, the technical session on Transfer Pricing (Room 1) took place, focusing on pathways to enhance tax certainty in developing economies. During this global forum, Jorge Santa Cruz, representing Mexico's Tax Administration Service (SAT), presented the analytical vision, operational challenges, and reservations of the Mexican government regarding the implementation of Amount B under Pillar One.

The core points of the presentation and SAT's official position are:

1. The Dilemma of Simplification vs. Local Market Reality

The OECD’s Amount B aims to establish a simplified approach with fixed margins for routine marketing and distribution activities. In this regard, SAT's position highlights:

• Risk of Undervaluation: There is concern that a standardized global model may not accurately capture the actual profitability of distributors in the Mexican market, which could result in the erosion of the local tax base
• The Arm's Length Principle: Mexico ratifies its strict adherence to the arm's length principle through detailed economic analyses, showing caution toward generic profitability matrices that disregard the specific characteristics of operations within the country.

2. Implementation Challenges and Administration Resources

Although Amount B theoretically aims to free up tax administration resources by reducing disputes in low-risk transactions, the speaker highlighted the complexity of its administration:

• Lack of Enabling Reforms: To date, domestic legislation (Income Tax Law) has not incorporated regulatory changes or miscellaneous rules to accommodate or transition legally toward Amount B.
• Segmentation of Operations: A critical technical challenge for SAT is the auditing of companies with mixed activities, as separating routine distribution revenues from those involving intellectual property or complex functions requires equally deep audits.

3. Mexico's Condition Under the OECD Political Commitment

Despite technical reservations regarding mandatory or widespread adoption in the short term, Mexico's status within the international community was analyzed:

• Inclusion in the List of Beneficiary Countries: Mexico is on the OECD list of middle-income jurisdictions that hold the "political commitment" of other member countries to respect Amount B outcomes if applied by the taxpayer, provided it aligns with local practices.
• Strategy on Standby: The Mexican position remains vigilant and undergoing a cost-benefit analysis, heavily influenced by the customs and tax stances of its primary regional commercial partners (such as the United States).

Executive Summary

For more information, visit the following link:

https://www.oecd.org/es/events/2026/06/oecd-tax-and-development-days-2026.html

https://www.youtube.com/watch?v=SlxemO7ywEc