The Mexican government recently enacted the requirement to file a master information return (Master file), local information return (Local file), and Country-by-Country (CbC) report on a calendar-year basis, starting in FY2016 (due by December 31, 2017). These provisions are consistent with the OECD’s Base Erosion and Profit Shifting (BEPS) initiative with respect to Action Plan 13: Guidance on the Implementation of Transfer Pricing Documentation and Country-by-Country Reporting.
The filing of a Master file and Local file is required by Mexican taxpayers exceeding the established threshold, while the CbC report is required only for Mexican multinational groups with group revenues in excess of the established limit. However, the tax authorities may also request a CbC report concerning foreign multinational groups. In both cases, a specific threshold for presenting documentation is established. The reporting must be filed electronically. Failure to file the reports is subject to fines and disqualification of the taxpayer from entering into contracts with the Mexican public sector.
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International Tax Services - Financial Services
, PwC US