Mexico Legislating On CbC Reporting Requirement
The 2016 Mexican Economic Package includes a proposal for country-by-country (CbC) reporting of tax information by certain multinational corporations.
The Package, which was submitted to Congress by the Government on September 8, 2015, seeks to bring Mexican transfer pricing documentation rules into line with the Organisation for Economic Co-operation and Development’s recommendations under base erosion and profit shifting (BEPS) Action 13.
CbC reporting envisages a three-tier reporting structure for MNEs. The master file would provide an overview of the MNE. The local file would need to include a detailed transfer pricing study, a group organization chart, as well as the taxpayer’s financial statements. The CbC report will specify some basic items of financial data in each country where an MNE is organized.
BEPS Action 13 recognized that enhancing transparency for tax administrations, by providing them with information to assess high-level transfer pricing and other BEPS-related risks, is crucial for tackling base erosion and profit shifting.
The CbC report must be filed within 12 months of the end of the financial year. A penalty is also proposed for non-compliance.
