“Turenna Ramírez is a business-oriented lawyer who understands the underlying problems and needs of the company and seeks comprehensive legal solutions in a clear and pragmatic way, which is very important and valuable for companies that need effective and quick solutions. We greatly appreciate Turenna Ramírez`s great commitment and exceptional skills in this field. Superficially, Mexican legislation follows – almost the book – the most important design principles of mandatory disclosure systems. This results from the ratio legis of the 2020 tax reform, which included the obligations of the reporting system in the Federal Tax Code, as well as the legal framework for subjects subject to disclosure, disclosure obligations and the consequences of non-disclosure. Despite this organization of provisions that follow the main design principles of Action 12 of the BEPS Project, some aspects of the national implementation of this type of legislation have been neglected by the Mexican legislator. Accounting records are properly kept for a period of five years (some exceptions may apply) and submitted digitally to tax authorities on a monthly basis. Generally, taxpayers are also required to file preliminary monthly tax returns and a final annual tax return. As regards VAT, taxable persons must submit monthly returns, which are considered final. Depending on the taxpayers` activities or the structure of the business, the filing of informative tax returns related to their participation in offshore legal entities or income received in jurisdictions considered tax-privileged under Mexican law may be mandatory. In addition, taxpayers can file additional tax returns that can be used to change or correct data submitted on previous tax returns. In these circumstances, despite national legal remedies, it would also be desirable to consider a more comprehensive analysis of the specific situation of the taxpayer in the event of a tax audit in order to have all possible alternatives. “Ivan Perez always responds to our requests within hours, and when we had to produce legal documents in a short period of time, the response from him and his team was quick.” An exception to the above rule has been included with respect to tax-transparent instruments that manage private equity funds invested in Mexican legal entities, subject to compliance with certain requirements, namely that the transparent vehicle and its members are tax residents in a jurisdiction with which Mexico has entered into an exchange of information agreement considered “broad-based” by the Mexican tax authorities. Becomes.
Chevez Ruiz Zamorripa`s international trade group works in perfect harmony with the firm`s respected tax department, assisting clients on a wide range of issues, including the tariff classification of goods for import or export; customs value, restrictions and non-tariff arrangements; controls carried out by the tax or customs authorities; the analysis of legal risks in the supply chain and for disputes against the actions and decisions of tax and customs authorities – a segment in which the practice has considerable capabilities. Guillermo Sánchez, an experienced litigator with extensive knowledge of the maquiladora industry; and Ricardo Romero, who is familiar with trade remedies – anti-dumping, subsidies and safeguard procedures – as well as regulatory issues related to imports and exports, are jointly responsible for the practice. Eduardo Díaz, who focuses on free trade agreements, World Trade Organization agreements, protection against unfair trade practices – dumping and subsidies – and antitrust law; and Gerardo Canseco (maquila operations, tariffs/valuation, free trade agreements, contractual supply chain and anti-dumping proceedings) are other names. Former partner Jorge Sánchez joined Deloitte in January 2022. While corporations are generally required to pay income tax through an annual tax return, estimated monthly preliminary tax returns (the amount of which is determined based on the results of the previous taxation year) must be filed. In addition, the rules of undercapitalization within the meaning of the applicable Mexican tax legislation must be respected. The eligible debt-to-equity ratio for entities resident in Mexico is 3:1. In general, interest on debts contractually exceeding three times the net assets of the corporation would be considered non-deductible for income tax purposes.