Tax Administration ServiceTax Administration Service

MexicoMexico

Tax Administration ServiceTax Administration Service

MexicoMexico

Mexican Tax Administration Service

President

AGGC

CAInternational Fiscal Audit

AGAAGAFF AGR AGJ AGAC Other Gral Admons

CA

Int Legal Affairs & Legal Criteria

CATransfer Pricing

CADiverse Taxpayers

CASector Gobierno

CALegal Disputes

CAConsolidated Corporations

CAPrograming

CAPlanning, Supervision & Evaluation,

CATax Collection

CALegal Affairs

CAInternational Fiscal Audit

Exchange of Information

Foreign ResidentsInternational Fiscal

AuditInternational Trade

Specific Atributions

(Art. 7 Tax Administration Service Law)

Crossborder Payments:

a) Foreign Earned Income

b) Deduction of Mexican Resident

Foreign Tax Credit

Investments in Tax Heavens

Permanent Establishments

Origin Verifications

Exchange of Information

Information

Sources

Auditor’s opinion for tax purposesTax Return Multiple Informative

Overseas Payments

Investments in Tax Heavens

Foreign Financing

Related Parties

Customs Database

Taxpayers Database & Tax Returns

Exchange of Information

Filed before Tax Returns

Audit Focus

Compliance

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)

Crossborder Payments

Foreign Earned Income

Audit Programs

Withholding rate (Law or Convention)

Compliance of the Convention

Tax Withholding and payment

Crossborder Payments

Deduction of Mexican Resident

Compliance of fiscal deductions regulations (Arts. 29 to 32 Income Tax Law)

Back to back credits (Art. 92 Income Tax Law)

Withholding tax and payment

Audit Programs

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.

Royalties

Related Parties Services

Artistes & Sportsmen

Leasing

Sale of Stocks

Crossborder Payments

Foreign Earned Income

Foreign Tax Credit

Determine the limit of the credit (art. 6 Income Tax Law)

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

Investments in Tax Heavens

Determine tax for 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

Permanent Establishments

Tax determination regarding PE’s

Verification of depreciation rates and amortization of assets

Allocated expenses

Intercompanies expenses from abroad

Audit Programs

Origin Verifications

Questionnaries

Visits to the premises of an exporter or producer

Verification

types

(exporter/producer)

Imports under preferential treament for customs tariff purposes

Audit Programs

Support area in charge of international matters related to nationals with foreign earned income

Exchange of Information

Spontaneaous

Automatic or Routine

Upon Request (Specific)

Types

Audit Programs