Transfer pricing adjustments can be anticipated with a correct assessment of the Business Group’s business model and support for compliance with the principle of full competition in intercompany operations.

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Fulfilling formal duties
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Transfer pricing consulting
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Support in litigation proceedings

To do this Jiménez Duarte Asociados
has a team of professionals that will allow you to:


Under the project implementation environment to prevent erosion in the G20/OECD Tax Base and Benefit Transfer (BEPS), identify the main risk or contingency factors against intercompany operations, considering the Business Group’s business model.


Make a diagnosis of compliance with the principle of full competition in intercompany operations, anticipating the end of the year.


Review of intercompany pricing policies and segmentation manuals.

In addition, we support you in the study of income attribution and occasional earnings for Permanent Establishments and Branches of Foreign Society. While the attribution study should only be submitted to the Tax Authority upon request by the tax authority, Permanent Establishments and Branches must have this analysis as support for their tax accounting and may therefore be required within the audit processes advanced by the Tax Reviewers.

In this area, Jiménez Duarte Asociados offers support for the review of the business model and the documentation of the functions, assets, personnel and risks assumed, evaluating compliance with the principle of full competition of attributable operations, as well as the rules contained in the Tax Statute on the realization of income, costs and deductions.

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