Dear clients and friends,
Through RULING dated January 26, 2021, issued by the Minister of Finance and Public Credit, published in the Federal Official Gazette on February 2, 2021, it is established that tax advisors or taxpayers will not be obligated to reveal the reportable transactions provided in Fractions II to XIV of Article 199 of the Federal Tax Code, as long as they are personalized reportable transactions and the aggregate amount of the tax benefit obtained or expected to be obtained in Mexico does not exceed 100 Million Pesos.
When there is more than one reportable transaction of the ones provided in Fractions I to XIV of Article 199 of the Federal Tax Code that involves or expects to involve one same taxpayer, implemented or expected to be implemented in at least one common tax year, and as long as they are personalized reportable transactions, in order to determine the 100 Million Pesos amount stated in the previous paragraph, what will have to be considered is the aggregate amount of the tax benefit obtained or expected to be obtained in Mexico through the totality of the mentioned personalized reportable transactions.
Should you have any questions related to the foregoing, please do not hesitate to reach out to your usual contact at the Firm.
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