US and Mexico renew competent authority agreement on unilateral APAs for maquiladoras

The United States (US) Internal Revenue Service (IRS) has announced that it has reached an agreement with the Mexican Tax Authority (SAT) to renew the competent authority agreement arrangement known as the Qualified Maquiladora Approach Agreement (QMA). Under the QMA, a US taxpayer can avoid double taxation on its maquiladora contract manufacturing and assembly functions by entering a unilateral advance pricing agreement (APA) with SAT’s large taxpayer division under terms agreed in advance by t…