Tax Administration Service
Mexico
Mexican Tax Administration Service
President
AGAFF
CA
International
Fiscal Audit
AGR
AGGC
CA
Transfer
Pricing
AGA
AGJ
AGAC
CA
Legal Disputes
CA
Planning,
Supervision
& Evaluation,
Other Gral
Admons
CA
Int Legal Affairs &
Legal Criteria
CA
Sector Gobierno
CA
Diverse
Taxpayers
CA
Programing
CA
Tax Collection
CA
Legal Affairs
CA
Consolidated
Corporations
CA
International Fiscal Audit
Foreign Residents
International Fiscal
Audit
International Trade
Exchange of
Information
Crossborder Payments:
a) Foreign Earned Income
b) Deduction of Mexican
Resident
Specific Atributions
(Art. 7 Tax Administration
Service Law)
Foreign Tax Credit
Investments in Tax Heavens
Permanent Establishments
Origin Verifications
Exchange of Information
Auditor’s opinion for tax purposes
Tax Return Multiple Informative
Overseas Payments
Investments in Tax Heavens
Information
Filed before
Tax Returns
Foreign Financing
Related Parties
Sources
Customs Database
Taxpayers Database & Tax Returns
Exchange of Information
Compliance
Audit Focus
Planning
Create awareness on taxpayers based on the constant
monitoring and analysis to detect agressive tax planning
and non compliance of international fiscal regulations
(surveillance)
Audit Programs
Withholding rate (Law or
Convention)
Crossborder
Payments
Compliance of the Convention
Foreign Earned
Income
Tax Withholding and payment
Audit Programs
Compliance of fiscal
deductions regulations (Arts. 29
to 32 Income Tax Law)
Crossborder
Payments
Deduction of Mexican
Resident
Back to back credits (Art. 92
Income Tax Law)
Withholding tax and payment
Most of the resources are used for auditing
corporations, nevertheless we seek to have
more fiscal presence in individuals.
Due to the significant increase in the turistic
and real estate industries, new audit
programs will focus on leasing operations of
individuals (turistic destinations)
Specific Audit Programs
Interests. Debt Planning.
Crossborder
Payments
Foreign Earned
Income
Royalties
Related Parties Services
Artistes & Sportsmen
Leasing
Sale of Stocks
Audit Programs
Determine the limit of the credit
(art. 6 Income Tax Law)
Foreign Tax Credit
Payment of tax effectively done
overseas
In 2004, 2,472 tax returns with foreign tax credit were filed for an
amount of $587 million pesos, representing a 72% increase with
respect to fiscal year 2003
Audit Programs
Determine tax for investments in
tax heavens
Investments in Tax
Heavens
File Informative Tax Returns
regarding such investments
Benefit for corporations with
enterprise activities that have such
type of investments
In 2004, 540 tax returns of corporations were filed, from which 63%
declared investments in stocks for an amount of $6,916 million pesos
Audit Programs
Tax determination regarding
PE’s
Permanent
Establishments
Verification of depreciation
rates and amortization of assets
Allocated expenses
Intercompanies expenses from
abroad
Audit Programs
Imports under preferential
treament for customs tariff
purposes
Origin
Verifications
Questionnaries
Verification
types
(exporter/producer)
Visits to the premises of
an exporter or producer
Audit Programs
Support area in charge of
international matters related
to nationals with foreign
earned income
Exchange of
Information
Spontaneaous
Types
Automatic or Routine
Upon Request
(Specific)