Mexican Tax Authority (SAT) Substantially Increases Transfer Pricing Tax Collections

On May 26, 2025, the Mexican Tax Administration Service (SAT) reported a 367% increase in tax revenue from large multinationals audits resulting from enforcing Mexico's transfer pricing rules. From 2019 through 2024, the SAT's revenue increased from roughly $1.5 billion USD (29 billion pesos) for the collection period from 2013 through 2018 to roughly $5.5 billion USD (106.18 billion pesos) for the collection period from 2019 through 2024. The SAT press release is available here.

Taxpayers in the automotive, mining, electronics, and telecommunications industries were among those multinationals under audit by the SAT's specialized transfer pricing department. Additional scrutiny on multinational audits in Mexico as well as the resulting revenue increase may point to increased compliance activity by the SAT.

Practice Point: Transfer pricing issues continue to be a focus of revenue departments around the world. With varying rules, large amounts at stake, and the need to do business in specific locations, multinational businesses are a target of increased scrutiny. If you have transfer pricing issues, consider reviewing your contemporaneous documentation at least annually to make sure it complies with the shifting requirements. In Mexico, for example, the SAT has stepped up enforcement. For information about the SAT's focus, see here.

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