Executive answer
Mexico’s related-party local information return applies to taxpayers within the categories referenced by Article 76-A of the Mexican Income Tax Law, or MITL, that enter into related-party transactions. It does not automatically apply to every Mexican company with an affiliate or to every member of a multinational group. The population is determined by testing each entity against the current references to Articles 32-A and 32-H of the Federal Fiscal Code and its actual dealings.
Current Article 76-A states that the local return is due by May 15 of the year immediately following the reported fiscal year. The master and country-by-country returns generally retain a December 31 deadline. This distinction matters because older SAT pages or instructions can still show the former timetable. The current statutory text controls the legal date, subject to confirmation of subsequent official rules.
The local return should not be built as an independent data-entry exercise. It summarizes organization, activities, controlled transactions, financial information and comparables. It should originate from the same inventory and analysis supporting the Article 76, section IX study, Anexo 9, the annual return and, where applicable, ISSIF or statutory-audit schedules.
Who is within scope
Article 76-A begins by referring to taxpayers described in Article 32-A, second paragraph, and Article 32-H, sections I, II, III, IV and VI of the Federal Fiscal Code that transact with related parties. The test therefore has two steps: establish whether the entity falls within a referenced Federal Fiscal Code category and establish whether it had related-party transactions during the fiscal year.
Build the map by Mexican tax registration number. One obligated sister company does not automatically make all group entities filers. A group may have one entity within an Article 32-H category, another subject to or electing statutory audit, and another outside the cited categories. Each conclusion should retain the legal basis, financial evidence and fiscal year.
The counterparty may be domestic or foreign. Article 76-A does not restrict the local return to cross-border dealings. Residence changes the facts, analysis and possible additional requirements, but it should not be used to exclude domestic transactions without a legal basis.
Before preparation, create an applicability sheet containing the Federal Fiscal Code category, controlled dealings, year, deadline, owner and evidence. Refresh it annually because thresholds, categories and circumstances can change.
What the local return contains
Article 76-A, section II, calls for information about organizational structure, strategic and business activities and related-party transactions. It also requires financial information for the filing taxpayer and for transactions or companies used as comparables.
Administrative rules and filing formats develop that content. In operating terms, the local return should identify the taxpayer and management; describe strategy and business; explain relevant restructurings or transfers; present transactions by category and counterparty; set out functional analysis, method, tested party, comparables, adjustments and conclusion; and connect financial information used in the analysis to the taxpayer’s statements.
The master file should not simply be repeated. The local return provides the Mexican taxpayer perspective. The master describes the group, business lines, intangibles, financing and global position. When the narratives conflict, the authority may ask whether the operating model has been described consistently.
Building it from one controlled source
1. Applicability and perimeter
Confirm the requirement by entity. Update the related-party population and dealings. Reconcile the ledger, electronic invoices, payments, agreements and master data. Assign a stable identifier to each transaction category. The identifier should follow the dealing into the study, Anexo 9 and reconciliations.
2. Organizational and business narrative
Obtain the local organization and reporting lines, management functions, strategy, markets, competitors and current-year changes. Avoid copying a global description that does not explain Mexico. The narrative should answer what the entity does, how it earns income, which decisions it makes and what changed.
Test interviews against agreements and conduct. If an agreement labels the company a limited-risk distributor but Mexico decides inventory, discounts and credit and bears losses, the label needs analysis. The local return should reflect facts rather than policy wording alone.
3. Controlled transactions
For each category identify counterparty, residence, amount, agreement, context, method, tested party, indicator, comparables and result. Separate services, goods, royalties, loans, guarantees, assets and restructurings. Do not aggregate merely to reduce data entry when different dealings require different profiles or methods.
4. Financial information
Prepare a bridge between financial statements and the figures tested. If the analysis is segmented, explain accounts, cost centers, allocations and eliminations. Retain workpapers and approvals. Accounting should validate segmentation prepared by the adviser.
5. Comparables and conclusion
Document search strategy, period, filters, accepted and rejected candidates, adjustments and range. The reported result should be reproducible. For internal comparables, identify the uncontrolled transaction and differences. For true-ups, connect calculation, entry, electronic invoice and tax returns.
6. Local-global review
Compare structure, value chain, intangibles, financing and restructurings with the master file, public reports and global agreements. Differences may be valid, but they should be identified and explained before filing.
Data-study-local return flow
| Local module | Primary source | Cross-check | Approver |
|---|---|---|---|
| Requirement | Federal Fiscal Code, MITL and taxpayer data | Audit, ISSIF and dealings | Tax |
| Structure | Corporate books and charts | Master file and legal records | Legal |
| Business | Interviews, budget and strategy | Agreements and conduct | Management/operations |
| Dealings | Ledger, invoices and master table | Anexo 9 and study | Accounting/tax |
| FAR | Interviews and processes | Agreements, personnel and approvals | Operations |
| Financials | Statements and segmentation | Annual return and subledgers | Controllership |
| Comparables | Search and workpapers | Study method and result | TP specialist |
| Filing | Software and final package | Approved version and receipt | Authorized signer |
Zugzwang’s Local File Sprint organizes sources, owners and reconciliations, tests local-global consistency and prepares a reproducible file before the May 15 submission.
Study, local return and Anexo 9 are different
The study documents the arm’s length analysis and underlying file. The local return is an information return for a specified population, structured around the entity and its dealings. Anexo 9 reports transaction fields through the DIM. They can share workpapers, but they are not interchangeable.
An efficient control model uses one master table and reusable modules. Functional analysis feeds the study and local return. Financial tables feed the local return and Anexo 9. The master provides group context. Reuse is not blind copying: each return requires its own perspective and granularity.
Deadline, language and submission
Under current Article 76-A, the local return is due May 15 after the reported fiscal year. The information is filed in Spanish. SAT provides a related-party declarations service and issues an electronic receipt. Confirm access credentials, technical requirements, annexes and availability before the deadline.
Retain the submitted package, annexes, source version, receipt and signature evidence. Do not retain only a rendered PDF where the software creates additional files. Log any rejection and resubmission.
If a general SAT page still shows the former December 31 local deadline, document that the reformed statute states May 15. The discrepancy is a reason to verify the current rule, not an option to select the more convenient date.
Common errors
The first is concluding applicability at group level. The second is using the former December deadline. The third is translating a global local file without adding Mexican facts and numbers. Other failures include omitted dealings, unchanged narratives despite real restructurings, unreconciled segmentation and nonreproducible comparables.
A local return may say Mexico does not control risks while board minutes show local decisions. The master may attribute an intangible to one entity while agreements or payments point elsewhere. Consistency does not require identical wording, but it does require a coherent explanation.
Recommended timetable
In January, confirm applicability and perimeter. In February, complete interviews, agreements and segmentation. Determine results and true-ups before the annual return. During April, freeze the master table and perform the local-global review. Reserve early May for technical review, data entry and signature.
If the return has already been submitted, perform a post-filing review against the final study, Anexo 9, annual return and master. Classify differences and determine whether correction or supplemental documentation is needed. Preserve the log for the next fiscal year.
Related topics
Management sign-off questions
Before signature, management should receive concise answers to five questions: why the entity is within scope, what changed from the prior year, which dealings and amounts are reported, which differences exist against the master file, and which true-ups or technical positions require follow-up. This summary does not replace the file, but it prevents signature from becoming a purely administrative act.
The approval package should contain the applicability memorandum, frozen transaction table, financial reconciliation, local-global matrix, final version and validation evidence. If the global master is not complete, identify the assumptions used and schedule a later comparison. The Mexican taxpayer remains responsible for its return even when it depends on information supplied from abroad.
- PT-004: 2026 calendar.
- PT-005: defensible study.
- PT-006: Anexo 9.
- PT-008: master file.
- PT-010 and PT-016: ISSIF and inventory.
Assembly and filing control
Build the Local File return from a field matrix that identifies source, transformation, owner and evidence. Corporate data comes from legal records; figures come from reconciled accounting; functions and method come from the approved study. A drafter should not manually alter amounts merely to make them agree without preserving a bridge. Every currency conversion, aggregation and reclassification must be reproducible.
Perform a cross-read: an operating owner challenges the functional description while an accounting owner traces figures. Then compare the DIM appendix, annual return, Master File and agreements. Explain legitimate differences through period, scope or reporting standard and correct the rest before submission.
Lock the filed version and retain the receipt, source files and approvals. If the portal forces a format or data change, document the screen, date and decision. Traceability turns the Local File return into a defensible synthesis rather than an isolated form.
Sources and verification date
As a final control, compare entity names, counterparties, methods and amounts with the prior filing. Investigate changes rather than rolling them forward silently. The reviewer signs the exception log and confirms that corrections reached every connected workpaper, return and narrative.
- Mexican Income Tax Law, current text, Article 76-A.
- Federal Fiscal Code, current text, Articles 32-A and 32-H.
- SAT related-party declarations portal, whose historical deadline should be compared with current law.
- OECD Mexico Transfer Pricing Country Profile.
Sources checked on August 2, 2026. Confirm applicability and software using the taxpayer’s facts and current rules.
If the local return is assembled from separate files or the Mexican narrative does not agree with the group file, request a consistency review before filing or amending it.