Foreign corporations under shelter program, might face a double cost of income tax
Flash Fiscal 54/2017
The Mexican Income Tax Law, as of 2014, established that residents abroad shall not be deemed to have a permanent establishment in Mexico for the following 4 years, or four years after contracting the “shelter” company.
In some cases, the 4 year period might be considered as a brief period to define the continuity of their manufacturing investment in Mexico.
As a preliminary analysis, we have found that through this administrative benefit granted by tax authorities, the foreign resident will have a double disbursement for income tax applicable to the same manufacturing activity.
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