Introduction In an unexpected move, the Mexican government and legislative introduced a sweeping tax reform for 2020, introducing mostly anti-abuse and anti-base erosion rules (the “Reform”). In one shot, the Reform introduces mandatory disclosure rules; a general anti-abuse rule; BEPS Action 7 permanent establishment definition into domestic law; an interest expense deduction limitation based on 30%…
Recently, a special Mexican Circuit Court (“the Court”) issued a ruling regarding the interpretation of an international convention (the North American Free Trade Agreement or “NAFTA”) which may signal broader guidance for the interpretation of treaties in Mexico. The case was ruled in order to resolve conflicting decisions by two Circuit Courts, as a result…
As a member of the Organization for Economic Co-operation and Development (“OECD”) Mexico[1] has been actively involved in the design and development of the Base Erosion and Profit Shifting (BEPS) Project and began implementing many of the recommended actions in 2014, even before the final BEPS reports were finalized in 2015. The execution and implementation…
