The Mexican tax reform proposal presented to congress on September 8, 2015 which includes supplementary transfer pricing documentation requirements in line with the three-tiered approaches of Action 13 of the OECD like master file and local file requirements and also Country-by-Country (CbC) reporting requirements. Under the tax reform proposal presented to congress on September 8, 2015, Interest-accruing debts incurred in constructing, operating or maintaining production infrastructure linked to strategic areas in Mexico will not subject to the thin capitalization rules.
The Budget proposals also includes the incentives for investing in energy and infrastructure sectors.
According to the tax reform proposal, non-compliance rules would be imposed penalties in a range of MXN 140,540 (USD 8,365) to MXN 200,090 (USD 11,910) and in addition, a failure to file or presenting incomplete or erroneous reports would be penalized by disqualifying the taxpayer from entering into contracts with the Mexican public sector.
