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Double Taxation Treaties (DTT)

International agreements

Objectives

Prevent evasion

Avoid double taxation

Legal certainty

use

Resides in one country

Income in another country

when

obtains

Promote investment

Méthods

Introduce texto aquí

Introduce texto aquí

are

Crediting

Exemption

Exempts income earned abroad

wich

are

The country of residence

responsible

Credits foreign tax against Income Tax (ISR)

International tax agreements with Mexico

Ministry of Finance and Public Credit

Tax Administration Service

Article 133 of the CPEUM (Mexican Constitution)

legal basis

Federal Tax Code

Income Tax Law (ISR Law)

More than 60 Treaties

generate

América

Europa

Asia and Middle East

Oceanía

United States, Canadá , Brazil Chile , Argentina

Spain, Germany, France, United Kingdom

Japan, China, South Korea, India, Israel

Australia, New Zealanda

Tax information exchange agreements

Agreements between countries to share tax information

Combat tax evasionl

Prevent tax fraud

Concealment of foreign income

types

Upon request

Automatic

Espontaneous

Specific information about a taxpayer

Exchange information periodically

Shares relevant information without being requested

Objectives

FATCA (with United States)

CRS (Common Reporting Standard) OCDE

TIEA (Tax Information Exchange Agreements)

important agreements

Withholding rates for dividends, interest, and royalties

Dividends

Interest

Royalties

Profits distributed by a company to its shareholders

Withholding rates in treaties

5 % → importante when the partner has a significant shareholding

10 % o 15 %

Loans, Financing, Bonds

In treaties:

4.9 %

10 %

15 %

rates

Use or exploitation of intangible rights

Patents, Trademarks, Copyright, Software, Technology

In treaties

5 %

10 %

15 %

pay

for

origin

payments

Treaties to avoid double taxation regarding Income Tax (ISR)

rates