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y the ISR Law can be offset in function of the customary use of said investments. If theinvestments can be identified only with the carrying out of either taxed acts or activitiesor exempt activities, they may be completely offset or not, depending on the case.If the investments are used for carrying out exempt or taxed activities without distinguishingbetween the two, the transferred VAT and the payment for the importation canonly be offset in the proportion that the taxed activities represent in the total value of theactivities that the taxpayer carries out in the month concerned, a proportion that may besubject to adjustments in the event that in subsequent months said proportion changesby more than 3 percent. The proportion that is determined should be applied withrespect to all the investments acquired or imported within a period of at least 60 monthscounted from the time of the offset.In those cases in which there is VAT transferred or paid for the importation of goods orservices or the granting of the use or enjoyment of goods or investments (made withoutdistinction to taxed or exempt activities), the taxpayer may choose to offset said tax forthe amount resulting from multiplying said tax by the proportion that represents thevalue of its taxed activities corresponding to the year immediately prior to the one forwhich the offsettable tax is calculated with respect to the total activities carried out duringthat period.4.6. Exportation of Goods or Services129Tax RegimeIn principle, the alienation of goods in Mexican territory is an activity subject to the VAT.However, the alienation of goods in Mexican territory that is carried out for exportationis subject to the VAT at a rate of 0 percent, which allows the taxpayers to offset the VATthat was transferred to them by their suppliers or that it paid for the importation ofgoods and that meets the requirements set out for offsetting. The taxpayer can evenrequest a refund of any credit balance that may exist.Despite the above, through miscellaneous tax provisions, certain alienations carriedout within Mexican territory of goods imported under certain customs regimes or ofnational or nationalized merchandise can benefit from the application of the 0 percentrate. The underlying reason for this is that it concerns the alienation of goods that,although not exported directly by export declaration, will be incorporated into otherproducts that will eventually be exported.In effect, the so-called IMMEX (in-bond manufacturing) companies that import merchandiseinto Mexico under the temporary importation regime can alienate such merchandiseto nonresidents as long as the merchandise is delivered within the country toanother IMMEX company or to companies in the automotive industry or car or auto partsmanufacturing industry, for its introduction into the customhouse deposit regime. Saidgoods can also be alienated to other IMMEX or Foreign Trade companies.