Abstract

MANCILLA RENDON, Ma.Enriqueta. Auditoría tributaria de los precios de transferencia de las multinacionales en México. Cuad. Contab. [online]. 2010, vol.11, n.29, pp.473-492. ISSN 0123-1472.

The legal framework in Mexico has established tax rules that regulate transfer pricing, especially after joining the Organization for Economic Cooperation and Development (OECD). The purpose of this study is to present the guidelines in Mexican tax law, regarding the rules followed by the tax administration when auditing large taxpayers (multinational enterprises) concerning transfer pricing issues, and in turn, how OECD Guidelines have influence Mexican Law, significantly in Income Tax Law (ISR) and the Federal Tax Code, establishing a special handling in the tax system. This is a documented fiscal study, based on current regulations, with original and official sources, as well as books and journals by various authors who have studied the select treatment of transfer pricing in Mexico, the Mexican tax administration approaching the OECD guidelines.

Keywords : Transfer pricing; OECD Guidelines; Tax Administration; methods; Multinational Enterprises; monitoring; Tax auditing; Organisation for Economic Cooperation and Development -OCDE-; Transfer pricing; International business enterprises.

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