Mexico: APA negotiation process; compliance with information requests

Mexico: APA negotiation process

The tax administration has initiated a process of sending information requests to maquiladora companies that are involved in negotiating and obtaining an advance pricing agreement (APA).


The information requested by the tax administration (Servicio de Administración Tributaria—SAT) concerns tax years until 2019. Taxpayers can submit their responses to the information request either via a tax mailbox or through an appointed representative (as notified with the SAT in Mexico City).

Once the information request is received, taxpayers have 10 business days to comply.

KPMG observation

To avoid the risk of delay or other negative consequences concerning their APA applications, taxpayers need to determine that there is full and correct compliance with the information request. Specifically, taxpayers need to be aware of the 10-day period allowed to comply with the information request and also of the requirement to use the tax mailbox or to coordinate communications between the tax administration and the taxpayer’s representative.

Read a March 2021 report (Spanish) prepared by the KPMG member firm in Mexico

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