MEXICO Law and Practice Contributed by: Jesús Aldrin Rojas, Miguel Ángel García Piña and Esteban Ollervides Toribio, QCG Transfer Pricing
QCG Transfer Pricing is a specialised practice fo - cused on delivering comprehensive and strategic solutions to transform transfer pricing systems into value drivers. The firm’s approach extends beyond a traditional transfer pricing practice, offering a unique blend of holistic solutions covering the entire transfer pricing structure with planning, legal, advisory and compliance solutions. QCG Transfer Pricing special -
ises in optimising value-chain structures, conducting robust benchmarking analyses, preparing compli - ance documentation, and providing expert support in controversy and defence matters. With a client- centric philosophy, the firm assists businesses at every stage of the transfer pricing process, ensuring alignment with global standards and enhancing op - erational efficiency.
Authors
Jesús Aldrin Rojas is the managing partner of QCG Transfer Pricing, with over 26 years of experience in transfer pricing and international tax, focusing on the OECD’s BEPS plan implementation. He is an external
Esteban Ollervides Toribio is a professional in the fields of transfer pricing and international taxation. He holds a bachelor’s degree in political science and public administration from the Autonomous University of
adviser to the Inter-American Centre of Tax Administrations, national co-ordinator of the Tax Committee at the Mexican–German Chamber of Commerce, and a transfer pricing professor in the master’s taxation programme at Panamerican University. An accountant and lawyer (UNAM), Jesús holds an MBA (ITAM) and a master’s in global management (Tulane University). He was Mexico’s first certified transfer pricing expert before the Federal Judicial Council. Miguel Ángel García Piña has over 20 years of tax experience, and worked for more than 17 years at Mexico’s Tax Administration Service (SAT), where he served as Administrator of Planning and Audit Programming for Large Taxpayers, focusing on detecting tax strategies and designing risk indicators. He is currently an international tax associate at QCG Transfer Pricing and a contributor to specialised publications such as International Tax Review, IDC Online, and Puntos Finos, among others. Miguel holds degrees in accounting and law from UNAM, along with a specialisation in administrative justice from the Centre for Advanced Studies of the Federal Administrative Justice Court.
the State of Mexico, as well as a bachelor’s degree in law from the National Autonomous University of Mexico (UNAM), where he also specialised in tax law. Esteban has published articles in leading journals in Mexico such as IDC, and co-authored pieces for International Tax Review, addressing topics like BEPS, transfer pricing strategies, and the fiscal impact of intercompany agreements.
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