Tax Management International Forum

I. Updates on BEPS-Related (or BEPS-Inspired) Measures or Proposed M

No amendment to the Mexican tax provisions has been enacted or proposed in response to the OECD's discussion draft on Branch Mismatch Structures, which was published on August 22, 2016.¹ More generally, Mexico has expressed its wish to continue adopting the BEPS Action Plan in a large number of forums. It is therefore expected that, over time, Mexico will implement measures based on BEPS Action Plan recommendations in areas where Mexican tax law is not already BEPS-compliant.

It should be noted in this context that, in accordance with the usual legislative practice in Mexico, amendments to the tax provisions are enacted annually. However, as noted in previous editions of the Tax Management International Forum,² in 2014, the Mexican Government issued a document titled ''The Certainty Agreement'' (''Acuerdo de Certidumbre Trib taria'') relating to tax matters. Under The Certainty Agreement, the