Wednesday, 9 August 2017

Mexico publishes final rules for Country-by-Country Reporting

Article 76-A of Mexican Income Tax Law (MITL), which went into effect on January 1, 2016, requires certain taxpayers in Mexico to submit the following three information returns: Master File, Local File, and Country-by-Country (CbC) Report. The deadline for filing 2016 returns is December 31, 2017.

The final rules — published by the Mexican tax authorities on May 15, 2017 — are generally consistent with Action 13 of the OECD’s Base Erosion and Profit Shifting (BEPS) initiative, generally called the CbC Report. However, for the Local File, the final rules may be viewed by some taxpayers as going beyond what is stated in Action 13 of BEPS and may require information that may not be available to the Mexican subsidiaries. As a result, some Mexican taxpayers may consider whether a constitutional trial (Amparo) against these additional obligations would be desirable or feasible.

Source & more info: PwC