New guidelines applicable to Mexican SOFOM structures

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In March, the Mexican tax authorities published a draft of their measure for applying the reduced 4.9% income tax withholding rate on interests paid by certain Mexican financial entities (’Sociedad Financiera de Objeto Múltiple’ or ‘SOFOMs’ in Spanish).

Taxpayers should thoroughly review their existing structures involving SOFOMs in order to properly assess any potential risk and adopt the corresponding measures in order to reduce such exposure. These provisions should be considered when using SOFOMs in future structures.

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Doug McHoney

International Tax Services Leader, PwC US

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