Mexico: Increased tax collection as a result of transfer pricing audits

The Tax Administration Service (SAT) on May 26, 2025, issued a press release (Spanish) announcing the recent results obtained from the implementation of its audit strategies and the analysis of the collection carried out for large taxpayers for the periods from 2013 to 2018 and from 2019 to 2024.\

Based on this statement, the following key points related to tax collection are identified:

• 2013-2018: 28,966 million Mexican pesos
• 2019-2024: $106,117 million Mexican pesos
• The increase in collection from one period to the next was 367%

The previous data is consistent and supports the message shared by the executive power since taking office: "A tax reform is not necessary at this time." In this regard, the executive also stated that if additional reforms are needed, they will be worked on over the next year, as there are still many opportunities for collection without the need for a deep tax reform.

At the beginning of the year, the SAT published the “Master Plan 2025,” with which this authority aims to reach its tax collection target for this fiscal year, which is $5.3 trillion Mexican pesos.

The master plan highlights the focus on programming and auditing, targeting the following sectors:

The increase in audit processes has focused on large taxpayers, which are mainly comprised of companies that are part of multinational groups. In Mexico, there are 16,131 large taxpayers, representing approximately 52% of the collection.

As mentioned in the Master Plan issued by the SAT, the continued use of technological tools to monitor and ensure compliance with tax obligations and the detection of irregularities include:

• Analytical techniques to monitor and detect irregularities in tax and employer obligations, as well as in the marketing and distribution of fuels
• Statistical learning models to identify irregular behaviors
• Identification and monitoring of atypical refund requests for value added tax (VAT), special tax on production and services, and income tax

KPMG observation

It is important for the management of companies belonging to multinational groups to assess their circumstances and risks regarding transfer pricing for periods that are open to potential tax review. Various legal means available may need to be examined to establish multilateral advance pricing agreements (APAs) in order to be prepared for possible scenarios of an audit by the Mexican tax authority.

Finally, for multinational companies undergoing a tax review process regarding transfer pricing, it is essential to explore options for accessing mutual agreement mechanisms incorporated in treaties to avoid double taxation.
 

For more information, contact a tax professional in Mexico with KPMG's Transfer Pricing and Controversy Practice:

Susana Galan | sgalan@kpmg.com.mx