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July 26, 2016
2016-1284

New OECD BEPS TP Guidelines: An analysis of possible conflict with Mexican Income Tax Law and Tax Treaties

The Council of the Organisation for Economic Co-operation and Development (OECD) approved the base erosion profit shifting (BEPS) Action 8-10 Reports on May 23, and formally incorporated the BEPS Reports into the OECD Transfer Pricing (TP) Guidelines. Mexican Income Tax Law (MITL) automatically incorporates OECD TP Guidelines "approved by the OECD Council" in its domestic tax legislation "to the extent they are consistent with Mexican income tax law and tax treaties."

This article, prepared by EY's International Tax Services group in Mexico, and attached below, provides additional details.

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Full text of Tax Alert 2016-1284

 

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