Global

Details

  • Service: Tax, International Corporate Tax, Global Transfer Pricing Services, Global Compliance Management Services
  • Type: Regulatory update
  • Date: 12/10/2012

Mexico - Tax treaties, transfer pricing documentation, IETU 

December 10:  In Mexico, the fourth amendment to the tax law for 2012 includes a list of new tax treaties or agreements, measures concerning transfer pricing documentation rules, and other measures.

The amendment (Cuarta Resolución de Modificaciones a la Resolución Miscelánea Fiscal para 2012) was published on 12 November 2012 in the official gazette (Diario Oficial de la Federación).

Tax agreements

Mexico has signed income tax treaties / agreements with Samoa, Belize, Costa Rica, and Bahrain.

Transfer pricing documentation

New rules allow taxpayers to opt out of the transfer pricing documentation requirement if the transactions are conducted at arm’s length prices between related parties and residents of Mexico whose income for the preceding year does not exceed 13 million pesos (approximately U.S. $1.01 million) and for taxpayers providing professional services whose income for the preceding year does not exceed 3 million pesos.

Other measures

Other items included in the recent amendments caution taxpayers concerning:


  • Rules for application of the income tax treaty between Mexico and Canada, the United States, Indonesia, or Panama with respect to a permanent establishment in Mexico and dividends and / or distributed earnings and profits
  • Rules on income from compensation paid for occupational injuries or disease
  • Rules on creditable tax for amounts of foreign tax paid by a foreign resident company
  • Rules on deferrals and contributions to Mexico’s IETU (i.e., the single rate business tax) with respect to contributions of property

Read a November 2012 report (Spanish) [PDF 98 KB] prepared by the KPMG member firm in Mexico: Cuarta Resolución de Modificaciones a la Resolución Miscelánea Fiscal para 2012




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