Private Equity Funds In Mexico – BEPS Concerns

Some years ago, it was very common to use foreign vehicles to promote and channel private equity investments in Mexico, such as Canadian limited partnerships, which were, and still are, widely used in Mexico considering their legal and tax transparency.

However, Mexico has undergone significant regulatory changes, including modifications that expanded the scope of allowed investments for investment companies specialized in retirement funds (SIEFORES).

Such modifications, together with other changes made to tax regulations in recent years, have broadened the type of vehicles (local and foreign) that are nowadays used in Mexico for this purpose, which include Canadian limited partnerships, US limited partnerships, US limited liability companies, several types of Mexican fideicomisos, such as regular non-business fideicomisos, real estate investment fideicomisos (FIBRAs), and private equity investment fideicomisos (FICAPs), among others.