🎧 Listen to This Article
Mexico’s Tax Administration Service (SAT) has seen a remarkable surge in revenue collection from transfer pricing audits, fueled by innovative enforcement strategies and cutting-edge technology. Between 2019 and 2024, SAT collected approximately 106.2 billion pesos ($5.5 billion) from large multinationals—an increase of 367% compared to the previous six years. This unprecedented growth marks just the beginning of what many tax practitioners describe as a revolution in Mexico’s approach to combat tax evasion and ensure multinational compliance.
Technology-Driven Enforcement
Central to this transformation is SAT’s strategic investment in advanced analytics and statistical learning models to monitor high-risk sectors. These technologies enable the tax authority to analyze vast troves of data, identify anomalies, and prioritize audits more effectively. As one industry expert notes, “They have a lot of information in their hands,” highlighting the enhanced data-driven capabilities of SAT’s enforcement team.
Transfer Pricing: A High-Stakes Focus
Transfer pricing—the valuation of intercompany transactions—has long been a complex area for tax authorities globally. Mexico’s sharp focus on this domain reflects an understanding of its critical role in preventing base erosion and profit shifting (BEPS). The SAT’s increasing audit activities have targeted large companies that historically exploited transfer pricing rules to minimize tax liabilities.
The 2025 Master Plan and Forward-Looking Strategies
According to the recently published 2025 master plan, SAT is not planning to slow down. Instead, it aims to deepen its auditing reach, improve risk assessment models, and leverage continuous technological enhancements. This forward-looking vision signals a sustained effort to close loopholes and strengthen Mexico’s tax base.
Implications for Multinational Corporations
For multinational corporations operating in Mexico, this evolving landscape necessitates heightened vigilance and robust transfer pricing compliance frameworks. Businesses must prepare for intensified scrutiny, enhanced reporting requirements, and potential disputes arising from the more sophisticated audit techniques employed by SAT.
Mexico’s aggressive transfer pricing audit program, underpinned by technology and strategic enforcement, is driving a significant increase in tax revenues and signaling a new era of compliance expectations. As SAT’s capabilities continue to grow, multinational enterprises must adapt swiftly to navigate this evolving regulatory environment.
For further details, clarification, contributions, or any concerns regarding this article, please get in touch with us at editorial@tax.news. We value your feedback and are committed to providing accurate and timely information. Please note that our privacy policy will handle all inquiries.
