As we discussed in our Fiscal Flash No. 005, on March 15, 2023, Mexico deposited the instrument of ratification of the Multilateral Instrument that modifies Bilateral Tax Agreements to implement BEPS measures (MLI). In Mexico, the MLI will enter into force in Mexico as of July 1, 2023 and with respect to taxes withheld at source (e.g. Mexico) on amounts paid or credited to non-residents, the Agreement will take effect as of January 1, 2024. Together with the deposit of the MLI, Mexico presented its reservations and notifications on the Bilateral Agreements covered by the MLI.

On June 19, 2023, the Decree Promulgating the Multilateral Convention to Implement the Measures related to Tax Treaties Aimed at Preventing the Erosion of Taxable Bases and the Transfer of Benefits, made in Paris, was published in the Official Gazette of the Federation. France, on November 24, 2016.

A Spanish translation of the Multilateral Instrument is included in this publication, as well as the aforementioned reservations and notifications of Mexico. However, it should be noted that the official version of the Multilateral Instrument was made in English and French, both texts being equally authentic, so the Spanish version published in the Official Gazette of the Federation is not official.

And could have deviations from the authentic versions in English and French, so we recommend reviewing each particular

At Fralla we are at your disposal to identify how, starting in 2024, the Multilateral Instrument will impact present and future operations carried out with people from other jurisdictions and with whom Mexico has entered into a Double Taxation Agreement.

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Mexico City, Mexico

June 2023