Given the growing competition and globalization of the encomia, the increase in the importance and complexity of operations between companies within Mexico or abroad have resulted in the creation of multinational groups, which is why it is necessary to provide legal and fiscal certainty. and financial management of the intercompany operations carried out, with the objective of complying at least with the requirements established in the BEPS action plan issued by the OECD and the increasing regulation and supervision of such operations by the tax authorities at the national and international level, having the need to have sufficient and reasonable elements that prove compliance with the transfer pricing obligations that are applicable to them, in accordance with the tax provisions and the most convenient valuation methods of operations that are required.