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OECD Recognizes Mexico’s SAT for Clearing MAP Backlog and Improving APA Performance

The recognition underscores progress under BEPS dispute‑resolution standards, signaling greater predictability for cross‑border taxpayers.

Overview

  • On Oct. 31 at the OECD’s Tax Certainty Day 2025, Mexico’s tax authority received first place for “Age of inventory” after eliminating its Mutual Agreement Procedure backlog.
  • SAT also earned second place as the “Most Improved Jurisdiction” for Advance Pricing Agreements, reflecting faster, more effective transfer‑pricing dispute prevention.
  • Officials said MAPs resolve double‑taxation issues after audits, while APAs set transfer‑pricing terms in advance to reduce the risk of future disputes.
  • Over the past seven years SAT concluded more than 120 bilateral agreements supported by about 60 double‑tax treaties across the Americas, Europe and Asia.
  • SAT reiterated its commitment to transparent application of laws and treaties, noting that strengthened certainty mechanisms have encouraged multinational investment in Mexico.