Due to the Mexican regulation of operations with related parties, intergroup transactions (domestic or foreign) need studies that allow them to timely comply with the requirements of documentation, analysis and information established by the Income Tax Law and regulating

provisions.

Mexican legislation in transfer pricing matter, combined with Mexico´s membership in OCDE and the signing of treaties to avoid double taxation with other countries implies that the companies that carry out operations with related parties must face similar needs in different countries at the same time, therefore the use of studies relative to intercompany transactions that involve transfer pricing is each time more urgent.

Alvarez Carmona y Asoc., S.C. seeks for its studies to go beyond the mere compliance with legal requirements; the Firm´s approach is the study of operations as basis of a strategy for the

optimization of the tax burden for the structure of the company, both in Mexico and abroad.

The Firm seeks for the transfer pricing analysis and documents to include:

The formation of an interdisciplinary team that combines tax and legal expertise with the most advanced techniques in financial, economic and accounting analysis, to prepare a final document that provides added value in the greater number of productive areas of the client.