Practice area

World TP Reviews

Transfer pricing
Baker McKenzie

The Baker McKenzie transfer pricing team in Mexico possesses thorough knowledge and experience in order to effectively manage the risks and opportunities inherent in local, regional and global transfer pricing strategies. It consists of lawyers, economists, tax advisors, public accountants and former high ranking members of tax organisations and regulatory bodies, including the OECD and national governments. It is the preeminent transfer pricing firm for the oil and gas, consumer goods and manufacturing industries in Mexico.

Over the past year, the firm has been involved in a number of high-profile cases, including its representation of a major Mexican oil and gas provider that consisted of advising a client with a business restructure in its gasoline wholesale and retail distribution segments, resulting from Mexican oil and gas sector liberalisations. The team also analysed different scenarios for the restructure in terms of the alignment of profit allocation with the functions and risk profiles of the parties involved.


BaseFirma has been in operation for 15 years, and is a part of an international group with offices in regions including Argentina, Uruguay and Venezuela. Its Mexican division is led by Raul Gustavo Lopez.

The firm’s transfer pricing practice in Mexico includes services in designing defence files, valuating tangible and intangible assets, negotiating APAs and MAPs with tax authorities, and implementing and documenting Action 13 of the BEPS programme.

Over the last year the firm represented a major company in calculating the sale price of an intangible, specifically a brand, in order to comply with the arm’s length principle, using the income approach method of valuation. The firm deals with a number of similar deals in Mexico and around the world.

The team welcomed Fernando Manzanilla as a senior manager to the practice recently.

Basham Ringe & Correa

Basham Ringe & Correa is an member firm of independent law firms network Lex Mundi and remains a highly regarded firm across Latin America. 

Alejandro Barrera, whose areas of specialisms include corporate tax, international tax, individual tax, tax planning and strategy, leads the firm’s transfer pricing practice. Its client list includes Fortune 500 companies and financial institutions.

Chevez Ruiz Zamarripa

The transfer pricing practice at Chevez Ruiz Zamarripa offers services in audits, tax litigation, business restructuring, economic and industry analyses for documentation requirements and assistance during MAPs. Oscar Campero leads the team of 28 professionals, which includes economists, public accountants and lawyers.

More specifically, the firm has recently handled diverse tax and transfer pricing audits related to the deductibility of pro-rata expenses, deductibility of advertising and promotion expenses and royalties, supply chain structures, geographic adjustments and sale of stock between related parties, among others. These cases were typically handled through Prodecon, or the Mexican tax authorities.

The team recently welcomed Pere Pons as a tax consulting partner, Valentin Ibarra, Gerardo Cansec, and Alfonso Garcia and as strategic administrative litigation partners and Rodrigo Adam as a tax wealth management partner.

Creel García-Cuéllar Aiza & Enriquez

Although an experienced transactional tax firm, Creel García-Cuéllar Aiza & Enríquez launched its transfer pricing practice in 2017, as well as a specialised social security practice. Its work is dedicated to transactional and high-value added work.

The firm’s recent transfer pricing experience is exhibited by its representation of ThyssenKrupp Industrial Solutions in an attribution of profits to permanent establishments. It addressed a plan to correct the tax situation of the Mexican branch of the industrial solutions company. As a result, the branch filed an amended tax return reporting the transfer pricing adjustment and favourable income tax balance that resulted from it.

The firm recently welcomed Laura Frias de la Parra as counsel in Mexico, and head of the firm’s transfer pricing practice.


Deloitte Mexico’s transfer pricing practice is the oldest and one of the largest transfer pricing specialist groups in Latin America. The team comprises 12 partners and 143 other professionals, many of whom have previously worked at the specialist transfer pricing unit at the Mexican Tax Authority (Servicio de Administration or SAT). Simon Somohano, who has more than 24 years of experience in the industry, oversees the practice. 

Moreover, Deloitte has leveraged technology-based solutions to assist multinationals to comply with the OECD’s BEPS requirements, such as country-by-country reporting, master files and local files. 

Skatt International Tax Firm

Emilio Angeles leads the transfer pricing practice at Skatt. The team is made up of one partner and three other fee earners who offer services across many aspects of transfer pricing including compliance, consulting and disputes advisory.

Over the last year the firm represented Johnson Controls Enterprises Mexico in a legal restructuring case. The Johnson Controls group requested a stock and business valuation of the companies of Johnson Controls Enterprises Mexico and three subsidiaries. The value of the business, $3.6 billion, was obtained through flows and was assigned to assets and liability for both companies to be valued. Through the methods established by the corresponding tax legislation, the value of the shares of the same companies including subsidiaries were determined to obtain a market value.

The firm recently welcomed Alan Montenegro, Luis Garcia, Uriel Olvera, and Paula Gutierrez as senior associates, and Jacqueline Villegas and Joceline Capula as junior associates.