Mexico Transfer Pricing Documentation Requirements
Mexico operates a genuine two-output regime. An annual contemporaneous transfer pricing documentation report must exist for taxpayers with related-party transactions, and a formal Local File and Master File must be filed where the revenue threshold is met, each on its own legal deadline. Penalties are fixed monetary amounts and can extend the audit period.
Requirements at a glance
| Requirement | Threshold | Deadline | Deadline type | Language | Penalty |
|---|---|---|---|---|---|
Master File Required | Revenue ≥ MXN 904m, listed companies, certain group regimes, and defined others | 31 December of the following year | Submission deadline The documentation must be filed with the tax authority by the date shown. | ES / EN | Yes (MXN 140,540 to MXN 200,090; audit period extendable to 10 years) |
Local File Required | Same thresholds as the Master File | 15 May of the following year | Submission deadline The documentation must be filed with the tax authority by the date shown. | ES | Yes (MXN 170,540 to MXN 240,090; audit period extendable to 10 years) |
TP documentation Contemporaneous report
Required | Taxpayers with related-party transactions | By the tax return filing date | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. Once requested, it must be provided within 10 days. | ES | Yes (informative-return penalties) |
CbC report Required | Group revenue ≥ MXN 12,000m | 31 December of the following year | Submission deadline The Country-by-Country report is filed by the group's ultimate parent entity; a local notification identifying the reporting entity is filed separately. | — | Yes |
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Scope of the documentation obligation
Mexico requires an annual contemporaneous transfer pricing documentation report from taxpayers with related-party transactions, which must exist by the tax return filing date. Separately, a formal Local File and Master File must be filed where the taxpayer meets the threshold conditions, principally prior-year revenue of at least MXN 904 million measured on the local entity, but also including listed companies, taxpayers under the optional group regime, government entities, and foreign taxpayers with a permanent establishment. These are distinct outputs with distinct legal deadlines rather than a single deliverable.
Distinctive features of the Mexican regime
The defining feature of the Mexican regime is that the contemporaneous documentation report and the formal Local File and Master File coexist on different statutory deadlines. The contemporaneous report must be in place by the return filing date, the Local File is filed by 15 May of the following year, and the Master File by 31 December of the following year, so a single taxpayer can carry three separate filing dates. Penalties are fixed monetary amounts, ranging into the low hundreds of thousands of pesos for each file, and a failure to file can extend the audit period from five years to ten, alongside collateral consequences such as a bar on supplying the public sector or withdrawal of an importer permit. A safe harbour applies to maquiladora operations under the IMMEX programme, where taxable profit is the greater of a 6.5 percent return on costs or a 6.9 percent return on assets.
Benchmarking and comparables
There is a preference for regional comparables, with Canadian, US, and Latin American companies accepted where their circumstances are similar to the tested party or appropriate adjustments are applied; there is no legal requirement for local comparables. While a three-year multi-year range was the traditional approach, recent audit practice and reform require further support for a multi-year analysis, applicable only where the business cycle warrants it. The tax authority prefers a fresh benchmarking search each year, a position reflected in the income tax law from the 2022 fiscal year. The assessment period is generally five years from the date the return is filed, suspended during an audit, with the authority allowed two years to complete a transfer pricing audit.
Frequently asked questions
Do the Mexican Local File and Master File share a deadline with the contemporaneous report?
No. The contemporaneous documentation report must exist by the return filing date, the Local File is filed by 15 May of the following year, and the Master File by 31 December of the following year, so a single taxpayer can face three separate dates.
Is there a safe harbour for maquiladora operations in Mexico?
Yes. Maquiladora operations under the IMMEX programme apply a safe harbour under which taxable profit is the greater of a 6.5 percent return on total costs or a 6.9 percent return on total assets.
This guide is an informational research aid prepared by Comp-Press and is not tax or legal advice. Transfer pricing rules change; verify current requirements before relying on them for filing.