Deloitte Mexico

A recent court ruling in Mexico has enabled the tax authorities to dive deeper into taxpayer affairs to determine whether transactions have real substance. Carlos Ramírez & Víctor Masón of Deloitte Mexico explain why taxpayers should take note of this judgment.

The SAT ruling now has expanded the situations where the 4.9% withholding tax rate is not applicable to include interest derived from certificates, loans and other financial transactions.

In order to provide legal and tax treaty certainty, such a concept should be included and described in legislation because, the mere use of it has a clear negative impact on such resolutions.