Research Report

Nearshoring Tax Risk Report 2026

Comprehensive analysis of tax implications and risk factors for companies nearshoring operations to Mexico and Central America.

48 pages
March 2026
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Executive Summary

The nearshoring wave represents one of the most significant shifts in global supply chain strategy in decades. Driven by geopolitical tensions, supply chain resilience concerns, and changing cost dynamics, companies across industries are relocating production closer to end markets.

Mexico has emerged as the primary beneficiary of this trend, with Central American nations also seeing increased interest. However, the tax implications of these moves are complex and often underestimated, creating significant risks for unprepared companies.

This report provides a comprehensive analysis of the tax landscape for nearshoring operations, identifying key risks and offering strategic recommendations for companies at every stage of their nearshoring journey.

Key Findings

65%

of US companies are actively considering or implementing nearshoring strategies

$12B

estimated annual FDI flow to Mexico related to nearshoring

3-5%

potential effective tax rate increase from suboptimal structuring

40%

of nearshoring projects face transfer pricing challenges

Report Highlights

  • Mexico Tax Reform Impact: Analysis of recent Mexican tax reforms and their implications for foreign investors, including changes to maquiladora regulations.
  • Transfer Pricing Deep Dive: Detailed examination of transfer pricing requirements and common pitfalls in cross-border manufacturing arrangements.
  • PE Risk Analysis: Evaluation of permanent establishment risks and strategies for managing cross-border activities.
  • IMMEX Program Guide: Comprehensive overview of the IMMEX program and how to optimize its benefits.

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Table of Contents

  1. 1.Executive Summary
  2. 2.Nearshoring Trends and Drivers
  3. 3.Mexico Tax Landscape
  4. 4.Transfer Pricing Considerations
  5. 5.Permanent Establishment Risks
  6. 6.VAT and Customs Implications
  7. 7.Central America Overview
  8. 8.Risk Mitigation Strategies
  9. 9.Recommendations