Transfer Pricing Declarations to be filed as a result of the 2024 Reform
The recent 2024 Tax Reform has introduced significant changes to taxpayers' Transfer Pricing obligations. The following diagram shows the Transfer Pricing Returns due for fiscal year 2024 resulting from this reform, highlighting the importance of understanding and complying with the new provisions to avoid potential tax contingencies, as well as the key points that companies should consider in this new tax landscape.
Author: C.P.C. & M.F. Rogelio Francisco Priego Castro
Obligation | Action | Next Due Date | Penalties for non-compliance |
BEPS Information Declaration: Local File | Expiration date is modified. | May 15, 2025 Previous deadline: December 31 | CFF 82-XVII and XXXVII $99,590.00 to $199,190.00 and $199,630.00 to $284,220.00 respectively |
Multiple Information Declaration (DIM) - Annex 9 | The reference to "residents abroad" has been eliminated. Transactions with domestic and foreign related parties should be included. | May 15, 2025 Previous deadline: March 31 or together with the ruling (SIPRED) | CFF 82-XVII from $99,590.00 to $199,190.00 |
SIPRED Fiscal Opinion 32-A second paragraph
| Individuals who, in the immediately preceding fiscal year, declared accumulated income equal to or greater than $1,855,919,380.00 are required to submit their financial statements. *To complete Annexes 16, 17, and 22 of the SIPRED, a Transfer Pricing Study must be submitted to support the information included. | May 15, 2025 Previous deadline: July 15 | CFF 84-IX from 17,330.00 to 173,230.00 |
Information statement on financial situation ISSIF 32-H Fracc VI | Taxpayers who are related parties to the entities established in the second paragraph of Article 32-A. *To complete Sections 15, 16, 18, and 21 of the ISSIF, it is necessary to have a Transfer Pricing Study that supports the information included. | March 31, 2025 Remains the same. | CFF 84-XV from 17,330.00 to 173,230.00 |
