Executive answer
Mexico’s fiscal-year 2025 statutory tax report filed through SIPRED in 2026 includes schedules and questions that expose the taxpayer’s position on related-party transactions. The existence of a study is not enough. Answers should agree with the trial balance, audited figures, Anexo 9, Article 76-A returns, agreements, true-ups and the registered public accountant’s conclusions.
Annex 16 of the 2026 Miscellaneous Tax Resolution, published in the Official Gazette on January 19, 2026, contains integration instructions and format-guide characteristics for fiscal-year 2025 financial statement reports. Depending on report type, it includes schedules covering related-party transactions, taxpayer information about those dealings and foreign-resident transactions.
The safest process is a matrix by SIPRED index. Every question receives the exact wording, source, amount, owner, reviewer, answer, explanation and study reference. Data entry is the final step; technical decision-making occurs before it.
SIPRED, ISSIF and the study are different
SIPRED is the system used to submit Mexico’s statutory tax report and connected information. The registered public accountant issues an opinion and the taxpayer supplies data. ISSIF is tax-situation information filed by taxpayers within Article 32-H of the Federal Fiscal Code. The study documents the arm’s length analysis. They can share amounts, but have different owners, bases and purposes.
The obligation or election to obtain a statutory tax report is reviewed under Article 32-A and current rules. Related-party transactions alone do not create SIPRED. Once within the report, those dealings feed schedules and questionnaires that require reconciliation.
The accountant does not replace management or the specialist. The company confirms facts, agreements and amounts. The specialist explains method and outcome. The accountant performs procedures and evaluates information for the report. Do not attribute a conclusion to the accountant that management never documented.
Information requested
Formats can request transaction type, counterparty, country, amount, method, indicators, range, adjustment and income tax withholding. They also include compliance questions: documentation, method application, arm’s length status, Article 76-A returns, unique and valuable contributions, VAT effects of true-ups and treaty use.
The 2026 Annex 16 describes a related-party schedule containing the tax value of the transaction, the adjustment used to reach independent-party conditions, modified amount and income tax withheld, among other data. Exact composition depends on the report type and format guide.
Use the applicable guide, not a generic list. Confirm the report model, SIPRED version, required schedules and data-entry rules before work begins. Retain the guide used.
Build an index-level matrix
Export relevant indices into a control sheet. Record number, wording, data type, requirement, source, preparer and reviewer. Link dependent questions so answers do not conflict. If the file says there is a true-up, related amount, VAT and return fields should be reviewed together.
Classify modules: population and relationship; transactions and amounts; method and comparables; true-ups; documentation and returns; foreign payments and treaties. Assign specialists. Accounting should not determine method. The transfer pricing specialist should not confirm withholding without tax. Legal validates agreements and residence. Operations validates FAR.
Record evidence using a stable path or identifier. An email saying “confirmed” is insufficient if it does not identify the source and competent person. Approve and retain the matrix with the report file.
Reconcile population and amounts
Begin with the related-party map and PT-016 inventory. Compare customers, vendors, payments, accounts, agreements, investments, loans, royalties, services and asset movements. Include domestic and foreign dealings according to applicable fields.
Reconcile totals to the audited trial balance and subledgers. Document VAT, exchange rates, nondeductible items, capitalization, accruals, credit notes, eliminations and true-ups. If SIPRED aggregates differently from Anexo 9, prepare a bridge rather than forcing equality.
Compare the final study and previously filed returns. If the statutory audit identifies a later difference, determine whether an amendment or explanation is needed. SIPRED’s later date does not automatically make a different figure correct.
Method, comparables and arm’s length answer
Report the method applied under Articles 179 and 180. Verify that tested party, indicator, range and result relate to FY2025 and the correct dealing. Do not copy another transaction code or the FY2024 study.
A question asking whether the transaction is arm’s length requires review of the result and true-ups. Having a range does not mean the tested result is inside it. If an adjustment was made, confirm its character and execution. If no reliable comparable existed, the explanation should agree with the selected method.
Unique and valuable contributions require functional and intangible analysis. Do not answer based on size or mere use of a brand. Review functions, assets and risks and preserve the judgment.
True-ups, VAT, withholding and treaties
The schedules connect transfer pricing to other taxes. A true-up can alter income, deduction, VAT, electronic invoices and withholding. Answer using the position and records actually adopted, not a pending recommendation.
For foreign residents, confirm country, relationship, amount, withholding, payment and treaty benefit. Transfer pricing does not itself prove residence, beneficial entitlement or treaty compliance. Retain certificates, agreements and calculations.
Escalate missing withholding identified in the audit before signature. Record correction, payment, inflation adjustment, interest and schedule effect.
SIPRED question-evidence-answer matrix
| Family | Source | Validation | Owner |
|---|---|---|---|
| Report and format | Federal Fiscal Code, rules and guide | SIPRED type and version | Accountant/tax |
| Relationships | Chart and rights | Master data and agreements | Legal |
| Dealings | Trial balance and subledgers | Anexo 9 and local return | Accounting |
| FAR | Interviews and processes | Agreements and master file | Operations |
| Method | Study and workpapers | Articles 179/180 | TP specialist |
| Result | Calculation, range and segment | Audited statements | TP/controllership |
| True-up | Memo, entry and invoice | Income tax, VAT and returns | Tax |
| Article 76-A | Memo and receipts | Entity-level requirement | Tax |
| Foreign resident | Agreement, payment and certificate | Withholding and treaty | International tax |
| Final answer | Approved matrix | Independent review | Management/accountant |
Zugzwang’s SIPRED TP Review turns every index into an evidence trail, reconciles dealings and coordinates technical answers among the accountant, tax, accounting and operations before signature.
Pre-submission review process
First confirm applicability, report type and format. Second obtain the prefilled file or index catalog and assign fields. Third close inventory and amounts. Fourth complete the study and true-ups. Fifth reconcile filed returns. Sixth perform independent review by risk and sample. Seventh enter, validate and compare the generated file to the approved matrix.
The accountant needs evidence before the last week. Establish an internal question and resolution deadline. Do not address differences at the end using generic additional information; investigate them.
Retain the submitted version, receipt, opinion, matrix, support and approvals. Control changes after signature.
Common errors
The principal failure is copying prior-year SIPRED. Others include using a preliminary study, omitting domestic dealings, confusing “documented” with “arm’s length,” reporting another method, stating an unexecuted adjustment and allowing a data-entry operator to determine technical answers.
Another error is for the accountant, adviser and company to maintain different tables. The same amount then appears under incompatible aggregations and currencies. Use one master table and transaction identifier.
After filing
Compare the submitted file and receipt to the approved matrix. Retain rejections and resubmissions. If a later correction affects the annual return, Anexo 9, local return or ISSIF, evaluate the full set. Record lessons for the next statutory report.
Situations requiring enhanced review
A recurring loss requires more than entering a negative margin. Review whether the study explains who controlled inventory, capacity, market or credit risk and whether SIPRED answers consistently. A restructuring requires identification of transferred functions, assets and risks, compensation and accounting. A new loan needs an aligned agreement, capacity analysis, rate, currency, term and withholding position.
For intragroup services, test transaction evidence, benefit and allocation in addition to method. For royalties, validate rights, use, rate, withholding and treaty support. For asset or share transfers, confirm value, date, method and documentation. These dealings do not share one evidence checklist.
Where management and the accountant disagree, record the question, evidence, each position and final conclusion. Additional information can explain a fact, but it cannot replace a mandatory answer or correct an amount. Escalate material disagreements before the report is issued.
Executive approval package
The CFO should receive a summary of reporting entities, material controlled dealings, true-ups, differences against filed returns, important negative answers and open issues. The accountant receives the detailed file. Management need not review every index, but it should understand positions with tax or reputational impact.
Confirm that the signed version is the reviewed version. Use a controlled repository, timestamp, owners and, where possible, a file hash. Any change after approval should return to the relevant reviewer.
Coordinating the closing calendar
The SIPRED workstream should begin before the annual return is final. In January, confirm scope and request schedules. In February and March, reconcile the preliminary ledger and resolve true-ups. After May filings, compare Anexo 9 and local return to the statutory-audit table. Reserve the final preparation period for audit evidence and conclusions, not transaction discovery.
Set response service levels for legal, operations, treasury and tax. A delayed answer on one loan or royalty can block several indices. The central matrix should show pending items, age, escalation owner and impact so that the registered accountant can plan procedures.
Related topics
- PT-004 and PT-005: calendar and study.
- PT-006 and PT-010: Anexo 9 and ISSIF.
- PT-012: consequences of noncompliance.
- PT-016: inventory.
Questionnaire traceability test
Before signing SIPRED, turn every questionnaire answer into a row containing question, answer, source, file, figure, owner and reviewer. Affirmative answers should link evidence; negative answers should link the analysis confirming absence. Do not reuse last year’s workpaper without validating changes in entities, transactions, forms and positions.
Select high-risk questions—method, adjustments, returns, documentation and financing—and reconstruct the answer from ledger, study and receipt. Then reverse the test: start from intercompany accounts and confirm the questionnaire captures them. Classify any difference as entry, scope, timing or technical position.
Accounting, tax and transfer pricing approve their fields, while one person controls the master version. Archive the filed questionnaire, workpapers, exceptions and receipt. This chain supports an audit response without discovering that every function used a different figure.
Sources and verification date
- Federal Fiscal Code, current text, Articles 32-A and 52.
- Annex 16 of the 2026 Miscellaneous Tax Resolution, published January 19, 2026.
- 2026 Miscellaneous Tax Resolution.
- Mexican Income Tax Law, current text, Articles 76, 76-A, 179 and 180.
Sources checked on August 2, 2026. Confirm report type, format guide, SIPRED version and taxpayer facts.
If the questionnaire is being answered without a matrix connecting every index to evidence, request a reconciliation before management and the accountant sign.