Written for Mexico. This analysis applies to Mexican federal tax law — ISR (income tax), IVA (VAT) and SAT rules — and cites Mexican statutes. Amounts are in Mexican pesos (MXN).
Does your company pay rent for its premises to another company of yours — or to you directly? Does the operating company buy services from the group's management entity? Did you lend money to your own company? Congratulations: you have related-party transactions, and with them, specific LISR obligations that most family groups only discover once the audit arrives.
What a related party is (it's broader than you think)
Two persons are related parties when one participates directly or indirectly in the management, control or capital of the other — or when the same group of persons participates in both (art. 179 LISR). In a typical family group, practically everything is a related party of everything else: your companies among themselves, you with each of them, and frequently your direct relatives and their companies too.
The three obligations that arise from operating between related parties
1. Price at market value
Every transaction between related parties — rent, services, interest, purchase and sale — must be carried out at the price that independent parties would agree on (arts. 76 section XII and 179 LISR). If the authority considers that it was not, it can adjust the price and determine the income or reject the deduction, with the tax consequences at both ends.
2. Document it: the transfer-pricing study
Since the 2022 reform, the obligation to obtain and keep supporting transfer-pricing documentation applies to related-party transactions that are domestic and foreign — the old myth that "that's only for multinationals" died that year. There are size-based exceptions (taxpayers with revenue below certain thresholds of art. 76 section IX in relation to 179), but the obligation to price at market value has no size exception: only the documentation requirement is modulated.
3. Report it
Relevant transactions with related parties are reported in annual informational returns. Skipping the report when the obligation applies means a direct fine and an audit trigger.
Do your intercompany transactions have a contract, a supported price and a report?
We map your group — all the entities and all the flows between them — and tell you which transactions need a contract, which need a study, which need a report and which are worth restructuring. It is one of the diagnostics with the highest immediate return: every gap found is a contingency defused.
The three flows most audited in family groups
- Rents on the owner's real estate (or their real-estate company) to the operating company: the classic. Without an appraisal or market reference to support the rent, the operating company's deduction is exposed and the landlord's income can be adjusted.
- Administrative or corporate services between group companies: the second classic, and the authority's favorite because it combines transfer pricing with substance: beyond the price, you must prove that the service existed (art. 69-B) and that it had a business reason (art. 5-A CFF).
- Intercompany and shareholder loans: without a contract, without a market rate and without real payment of interest, they can be recharacterized — as a dividend, as presumed income, or as a capital contribution, whichever suits the authority, not you.
Frequently asked questions
I only have one company and I lease my premises to it as an individual. Does this apply to me?
Yes. You and your company are related parties. The rent must be at market value and supported; your company deducts it and you report it as income. It is the most common related-party transaction in Mexico and one of the most audited.
Do I need a formal transfer-pricing study every year?
It depends on your revenue and the type of transactions (the thresholds in section IX of art. 76 modulate the documentation obligation). What does not depend on size: pricing at market value and being able to prove it. For mid-sized groups, well-done proportional support is usually enough and far cheaper than the adjustment.
What happens if I have been operating this way for years without documenting it?
The authority's audit powers reach back over the last five fiscal years. The sensible route: regularize going forward immediately and assess the backward exposure to decide — with numbers — whether self-correction is worth it on anything. That is decided case by case, not out of panic.
Let's talk about your case
Every structure, every transaction and every family is different. The first step is always the same: an honest diagnostic of where you stand. Write to us on WhatsApp or call — a reply the same business day.