The Mexican Tax Administration Service (SAT) and the United States Internal Revenue Service (IRS) have renewed the Qualified Maquiladora Approach (QMA) or «Fast Track» Agreement. This renewal is a result of collaboration between the tax authorities of both countries and maintains the core elements of the QMA transfer pricing framework applicable to fiscal years 2019 and prior.
Key Points of the Update
1, Eligibility for Resolutions 2020-2024
Only maquiladoras that meet the following criteria can obtain a resolution applicable for the fiscal years 2020 to 2024:
- Have requested, obtained, and correctly implemented a resolution for the fiscal year 2019 and prior, or
- Have correctly applied the provisions of Article 182, first paragraph of the Income Tax Law (LISR).
The resolution must not be under dispute in any legal defense means. If it is, the dispute must have been withdrawn, and the resolution must have been correctly implemented or the provisions of Article 182, first paragraph of the LISR must have been correctly applied.
2. Updated Methodology
With this new approach, Advance Pricing Agreements (APA) for the period 2020-2024 can be resolved by applying a new methodology for determining the prices of compensation for maquila services provided to foreign residents with whom they operate.
Access to the SAT Microsite:
For more information, you can access it here.
