International taxation for foreign residents with Mexican source income

As a consequence of the increase in the number of treaties formalized by Mexican authorities in order to avoid double taxation, and multiple significant changes to the OECD’s Model Tax Convention associated to the BEPS action plan, it is necessary to analyze the tax implications of transactions carried out by foreign residents in Mexico (for example, permanent establishments, tax residence, tax treatment of royalties, technical assistance, interests, expatriate personnel, etc.) so that Mexican taxpayers, or the foreign residents mentioned above, are able to apply the benefits afforded by said treaties and avoid the subsequent undesirable effects of international double-taxation.

Our Firm advises taxpayers on the correct application of the different provisions of the diverse Income Tax conventions, specific actions of the BEPS plan launched by the OECD, mandatory disclosure rules as per the Mexican Tax Code, as well as in tax reviews performed by SAT on any of these areas.