Traducciones De Negocios

|Transfer Pricing |







Transfer Pricing Analysis
Fiscal Year 2011
National Related Parties


BSM, S.A. DE C.V.






INDEX


I. Introduction 5

II. BSM Business Description 5

a) History 5


b) Description of the group 6Organizational Structure 6

III. Related parties information 7

IV. Functions and risks 7
Functions 7

Research and development 7


Services 7

Risks 7

Occupational hazard 7


Market risk 7


Collection risk 8


Currency Risk 8


VI. Information on transactions with related parties BSM. 8

Description of the methods available 10Method comparable uncontrolled price (CUP) 11


Resale Price Method (RPM) 12


Cost Plus Method (CPM) 13


Partition Method Utilities (MPU) 14


Residual Method Partition Utilities (MRPU) 14


Margin Method Transactional Operating Profit (TOPMM) 14

Concept analyzed part 15

VIII. Administrative services. 16


1) Determination of financial results forrelated party transactions 18

6. Search results 24

Accounting adjustments 25


Using the interquartile range 25


IX. INTEREST EXPENSE DOLLARS 28

A. Selecting the most reliable method 28
B. Implementation of CUP 29

1. Methodology used 29


Credit quality 32


Application of CUP to analyze loan 32


Interquartile range 33


Results 33X. TRANSACTIONS AGREED WITHOUT PROFIT MARGIN 35


a) General 36


b) Analysis and Results 36


XI. Conclusions 37







Introduction


The purpose of this section is to present the results of our analysis of transfer pricing on transactions conducted by BSM, SA de CV (hereinafter "BSM") with its related parties in country resident Brose Reynosa, SA de CV(hereinafter "BROSE RYN"), Brose Puebla, S.A. de CV (hereinafter "BROSE PUE") and Brose Mexico SA de CV (hereinafter "BROSE MX"). The results shown below include the analysis of transactions with related parties included in national Annex C.


This analysis is intended to determine whether the transaction made by BSM with its related parties resident in national territory, was performed according to theprinciple of market value (Arm's Length Principle). For purposes of the above, was applied to one of the methods listed under Article 216 of the Law on Income Tax (Income Tax Law) and with the provisions of section III of article 18 of the Law of the Single Rate Business Tax ("LIETU ").


BSM Business Description



BSM, S.A. de C.V.

BSM is a Mexican company founded in January 1996,whose main business activity is the provision of personnel services exclusively to its related parties residing in Mexico. It should be noted that in April 2008 he joined the staff at Brose BSM Reynosa.


History


Brose Group was founded in 1908 by Max Brose in Wuppertal Germany, as a company dedicated to the marketing of auto parts among which included lights, automotive tools, mirrorsand speedometers and others. Later in 1919 he founded with partner company Ernst Jühling Metallwek Max Brose & Co., which was devoted to the further manufacture of auto parts and components.

In 1926 he patented a rotor used to lower the car windows, and two years later began mass production of the product, becoming a leader in that segment sale. Additionally in the 1950s began to include itsauto parts in Volkswagen cars, Mercedes Benz, Ford and Opel among others.

Later in 1960 developed the first seat adjusters, which were used in various models of Mercedes Benz and BMW mainly. Additionally, in the late 1980s began Brose Group internationalization by opening production centers in England and Spain, in 1993 opened the first plant in Latin America, in Queretaro Mexico.

Currently...