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  • Interest Deduction at 30%: Outstanding Issues According to César Gámez
    Outstanding Issues and Effects of the 30% Limit on Interest Deductibility Article by César Gámez in Puntos Finos The rule that limits the deduction of net interest to 30% of the Adjusted Taxable Income (UFIA)—adopted in Mexico since 2020 in line with Action 4 of the OECD’s BEPS Plan—still presents gaps that affect corporate tax planning
  • Deloitte | tax@hand - taxathand. com
    One of the most significant tax reforms enacted in Mexico that has been effective since 2020 involves the limitation applicable to the deduction of net interest expense based on the Income Tax Law (LISR), which is referred to as the “nondeductibility of net interest ” The LISR has been amended to indicate that the nondeductibility of net interest may be determined in a consolidated manner
  • DRAFT - Argentina Mexico Peru - EY tax_agenda_July 2024 - TQ
    Action 4 Financing transactions subject to an interest limitation rule In addition to the 3:1 debt to equity limitation, net interest expense is subject to a deduction limitation equal to 30% of tax EBITDA The limitation applies to related and non-related party transactions as well as debt between Mexican and nonresident entities
  • Tax Agenda Mexico - EY
    Financing transactions subject to an interest limitation rule In addition to the 3:1 debt to equity limitation, net interest expense is subject to a deduction limitation equal to 30% of tax EBITDA The limitation applies to related and non-related party transactions as well as debt between Mexican and nonresident entities
  • Mexico - Corporate - Deductions
    In general terms, interest expenses are deductible items if, among others, the principal is invested in the main activity of the Mexican taxpayer, withholding obligations are complied with, informative returns disclosing information related to the loan and transactions carried out with related parties are filed, thin capitalisation rules (3:1
  • Mexico Legal Guide to: Business Investment Expansion
    As a general rule (excepting some economic activities contemplated by foreign investment laws), foreign investors are allowed to conduct business in Mexico without a local partner, either through a: i) branch (sucursal), ii) representative office (oficina de representación), or iii) a subsidiary (Mexican entity)
  • Foreign Investment Regulation: Mexico - Lexology
    Foreign Investment Regulation: Mexico - In-Depth: Foreign Investment Regulation (formerly The Foreign Investment Regulation Review) is an insightful guide to the laws, regulations, policies and
  • Doing Business in Mexico
    The only exceptions to that general rule are those expressly established in the FIL itself (discussed in the section “Restricted activities under the FIL” below) or, in the case of the financial sector, in the legislation covering that sector This new regulatory framework replaces the restrictions of the old foreign investment law, which generally limited foreign investment in Mexican
  • Mexico
    Thin capitalisation rules disallow the deduction of interest on debt owing to foreign related parties if the total amount of interest-bearing debt exceeds a three to one debt equity ratio
  • Global tax guide to doing business in Mexico - Dentons
    As a general rule, registering a Mexican branch requires authorization from the General Bureau of Foreign Investment of the Ministry of Economy Determined on a case-by-case basis, a Mexican branch may constitute a PE in Mexico for tax purposes
  • Mexico Action 4 implements BEPS deductibility to limit interest
    O n October 30 2019, the Mexican Congress approved the 2020 tax reform which, among other amendments and additions to several tax provisions, included the incorporation of a new subsection to Article 28 of the Mexican Income Tax Law in order to limit the deductibility of interest payable by companies in a given tax year in accordance with Action 4 of the OECD BEPS project Through the





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