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Mexico<br />

2.7 Current <strong>tax</strong> <strong>policy</strong> and <strong>tax</strong> administration<br />

leaders<br />

Tax <strong>policy</strong> leaders<br />

• <br />

• Luis Videgaray Caso, Secretary of Finance and Public Credit<br />

• Miguel Messmacher, Undersecretary of Revenue<br />

• <br />

<br />

• José Francisco Yunes Zorilla, Chairman of the Finance and<br />

Public Credit Commission, Senate<br />

Tax administration leaders<br />

• <br />

• <br />

2.8 K<strong>ey</strong> <strong>tax</strong> <strong>policy</strong> changes in 2014<br />

• In addition to the 2014 Tax Re<strong>for</strong>m, the following regulations<br />

and rulings have been issued:<br />

• Mexican <strong>tax</strong> authorities issued temporary <strong>tax</strong> regulations<br />

<br />

no. 76) to comply with the obligation to report so-called<br />

“relevant transactions.” In March 2014, the Mexican<br />

Supreme Court issued a ruling that allows the deduction<br />

of pro rata expenses paid to residents abroad so long as<br />

certain requirements are met.<br />

• Temporary <strong>tax</strong> regulations (details) on reporting<br />

accounting through electronic systems were issued in<br />

July 2014.<br />

• Temporary <strong>tax</strong> regulations were issued on maquila<br />

transactions (permanent establishment exemption) in<br />

July 2014.<br />

• <br />

with respect to royalties, interest or technical assistance<br />

payments per<strong>for</strong>med by a Mexican entity considered<br />

transparent <strong>for</strong> the purposes of <strong>for</strong>eign legislation.<br />

• In November 2014, the Mexican Supreme Court issued<br />

a ruling granting a temporary stay of execution of<br />

<br />

amparo lawsuit.<br />

2.9 Country position on OECD Base Erosion<br />

and Prot Shifting (BEPS) Action Plan<br />

• <br />

BEPS Action Plan, making interest, royalties and technical<br />

assistance payments to a <strong>for</strong>eign entity that controls or<br />

is controlled by the <strong>tax</strong>payer non-deductible if the <strong>for</strong>eign<br />

entity is a transparent entity; the payment is considered in<br />

the recipient country as nonexistent or the <strong>for</strong>eign entity<br />

does not consider the payment as <strong>tax</strong>able income. Payments<br />

to a related party are nondeductible if the same payment is<br />

considered as a deduction by another related party resident<br />

in Mexico or abroad.<br />

2.10 Pending <strong>tax</strong> proposals<br />

• PAN Congressmen (Partido Acción Nacional) are attempting<br />

to reintroduce a 11% VAT rate (border zone rate).<br />

• PAN Congressmen are trying to reintroduce an immediate<br />

deduction <strong>for</strong> income <strong>tax</strong> purposes (the immediate deduction<br />

was eliminated with the 2014 Tax Re<strong>for</strong>m).<br />

2.11 Consultations opened/closed<br />

• Not applicable<br />

• In September 2014, temporary <strong>tax</strong> regulations on VAT<br />

refunds were issued (refund on a maximum 20-day period)<br />

<br />

projects provided certain requirements are met.<br />

• <br />

to detail and to add other requirements to pro rata<br />

expenses deductions.<br />

The <strong>outlook</strong> <strong>for</strong> <strong>global</strong> <strong>tax</strong> <strong>policy</strong> in <strong>2015</strong> | 133

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