MEXICAN TAX REFORM 2014

Tax Alert 06/2013
2014 Mexican Tax Reform
On September 8, the Executive Power filed before Congress the Economic Package for the 2014 fiscal year. The Economic Package includes not only the General Criteria for Economic Policy, the Federal Revenue Law and the Federations’ Expenditures Budget, but also a series of initiatives to modify current tax laws and even the enactment of new legislation.
Among the highlights there are the amendments to Income Tax (ISR), Value Added Tax (IVA), the Special Tax on Production and Services (IEPS) (excise tax), the abolishment of the Flat Rate Business Tax Law (LIETU) and the Cash Deposits Tax Law (LIDE), as well as the new rules around the Universal Social Security (SSU), the universal pension and the unemployment insurance.
The aforementioned reform has a clear tax collection tone, although possibly insufficient for the purposes it is seeking on closing the gap between the levels of tax collection that our commercial partners have, as well as to free PEMEX from a tax burden so that it may grow as an enterprise. It has been stated that the reform does not contemplate other elements that could have been included, acknowledging that the world and the local economic situation are not going through the best of times, and proof of it is that it abandoned the idea to standardize the tax burden for purposes of IVA on food and medicines.
The objective proposed, is the generation of employment and support to the economy through a counter cyclical effort, however, there are no programs created or launched to stimulate investment or employment, on the contrary.
Below are the main changes and adjustments to the tax system, which will be discussed and, if applicable, approved by Congress.
Income tax law
Corporations
The compromise to reduce ISR rate to 29% for 2014 and 28% for 2015 would be eliminated since under the new Income Tax Law the 30% rate would be permanent. The Primary Sector (agriculture, cattle, fishing, and forestry activities) would now be subject to this rate, who until now enjoy a reduction of up to 30%, with the purpose of eliminating preferential tax treatment.
Tax Incentives, such as the accelerated depreciation of fixed assets, as well as land deductions for real estate developers and the special regime of the SIBRAS (Real Estate Investment Companies) (the FIBRAS –Real Estate Investment Trusts- regime is maintained with some adjustments) would be eliminated.
Tax Consolidation as we know it would cease to be applicable starting January 1 2014 and the “deferred taxes” would be covered through time under its own rules, giving way to the new regime of “Tax Integration”, simpler that the one before it, but with certain additional requirements for its application.
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The bill proposes to eliminate from Income Tax the Simplified Regime, the particular rules for the sales in installments, as well as the special rules on the costs budgeting for real estate developers, immovable goods construction or long term fixed asset manufacturing contracts.
As part of the reforms, it is suggested to eliminate the deductions for restaurant consumptions and the social security workers fee paid by employers. ,Also it has been proposed to reduce the amount by which an automobile can be deducted to 130,000 pesos (down from 175,000) and reduce the amount to deduct for the daily rent of automobiles to 200 pesos (down from 250). It is worth mentioning that with respect to some specific deductions such as the contributions to pension and retirement plans, the rule would be modified so as to defer the deduction until the events or payments occur, and in case of the preventive reserves (bad debt) of banking and insurance institutions, the proposal is aimed towards not being deductible, until they have occurred.
For the specific case of the mining industry, it is proposed to eliminate the currently existing option that allows deducting the pre-operative expenses in the year these are incurred.
Regarding the workers profit sharing (PTU) the proposal is to eliminate the specific article currently enforced so that the basis of determination is under the same ones as the ISR, but with the exception of reducing the PTU basis with the tax loss carryforward.
The proposal also contemplates to adjust or modify the tax cost of shares calculation and the method of crediting foreign taxes, and new requirements are included to apply for benefits under the conventions to avoid double taxation with a view to avoid abuses that would result in double non taxation.
With respect to the maquiladora sector, it is proposed to modify this preferential tax regime to limit it only to such companies that export at least 90% of its production. The so called “shelter maquilas” would have a 3 year period to modify its operations.
The proposal of Tax Reform includes the creation of an additional tax of 10% for companies over the dividends that they pay to individuals and foreign residents, which would be characterized as a definitive payment.
Non-profit entities.
With the objective of promoting donations to authorized private non-profit entities, it is proposed to establish a threshold to the deduction for donations that taxpayers perform in favor of the Federation, the States and Municipalities, fixed at 4% of the taxable income of the taxpayer in the immediate previous year. With this measure, it is expected to incentivize the donations to private non-profit entities given the fact that the deductibility limit to these entities is 7%.
Currently all of the private institutions dedicated to education are considered as entities not subject to ISR. With this initiative, it is expected for these institutions to be considered as subject to ISR unless they obtain or keep an authorization to receive tax deductible donations.
Based on the aforementioned, if a civil association or society that is dedicated to render educational services does not have such authorization it will be a taxpayer according to Title II of the Law as any other legal entity, with the exception of the moment when the income is recognized, which will be at the moment when the price or agreed consideration is paid. The same will happen with the institutions dedicated to sports purposes, which are proposed to stop being considered as non-taxpayers.
It is intended to increase the listing of the activities that charitable and assistance institutions may undertake to include the following (i) promotion of citizen security actions, (ii) civic, focused to promote citizen participation in matter of the public interest, (iii) support to the indigenous communities and towns, (iv) promotion of gender equality and (v) contribution of services to support handicapped social groups.
It is proposed that the non-profit organizations be empowered to influence in the legislative reforms, as long as its intention is to support social or industrial groups, or economy sectors that may be benefited with a legislative framework that improves the relationship between the state and its citizens.
Individuals
The first aspect to highlight is that the proposed reform includes a raise in the rate to 32% for every individual that reaches an income higher than 500,000 pesos. It does not suggest any modification to the current structure on the ranges of taxation.
In addition to the aforementioned rate increase, the personal deductions are sensibly reduced, that up until now, they remained practically limitless, with the exception of some cases such as mortgage interests, to establish a
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maximum threshold of such deductions equivalent to the lower of 10% of the total income or two annual minimum wages, which will in reality render the tax payment for all levels of income higher than it currently is.
In the case of the sale of homes, the exempt amount is also reduced from 1,500,000 UDI’s (equivalent to 7.5 million pesos) down to only 250,000 UDI’s (equivalent to 1,200,000 pesos).
Transactions in the Stock Exchange could be levied in case the proposal is approved, on a rate of 10% on the gain. The tax should be paid directly by the investor and any losses incurred during the last 10 years could be applied against the gains.
With the objective to attract more taxpayers to the formal economy, it is proposed to create the so called “Incorporation Regime”. This option will be applicable to whoever has a business activity, sell goods or render services for which a professional title is not required. This new regime expects to grant a gradual transition of 6 years where the ISR will be increasing and will grant a full exemption on the first year, in such a way that by the seventh year, the individual will be paying taxes under the general regime. As an incentive, it suggested to provide these persons with access to social security for no cost during the first 5 years.
Foreign Residents
In those cases where the foreign residents opt for the income tax payment over the gain obtained in the share disposition with the source of income in Mexico, the reform would increase the tax rate to 32% and substituting the Registered Public Accountant opinion (dictamen) in exchange of filing certain information as required by the provisions set forth in the Rules for the new Income Tax Law or the rules that for such effect the SAT will issue. As such, the obligation to designate a legal representative in Mexico is still included in those cases.
With the intention to standardize the applicable provisions for Real Estate Trusts with the exemption provided by Title V for the pension and retirement funds that enjoy exempt status for income tax purposes on its countries of origin, is established as a new requisite that the real estate goods acquired or developed be destined to provide the temporary use or enjoyment for a period no less than four fiscal years.
Similarly, the exemption on the gains derived from the sale of land or constructions adhered to the soil when these are obtained in the undertaking of business activities in the county is eliminated, as it is not consistent with the activities of the pension and retirement fund from the point of view of the Executive Power.
It is stressed that any expense that a Mexican resident absorbs on behalf of a foreign resident, that in effect avoids a disbursement to the latter, including the corresponding tax, will be considered to form part of the income of the foreign resident subject to the same rules applicable to the type of income for which a tax was paid. In other words, it eliminates any doubt related to the “gross-up” on the basis that originated a tax payment for income sourced in Mexico.
A withholding rate of 5% is established over the use or enjoyment of tow trucks and semi tow trucks property of the foreign resident that are used for the transport of goods.
The application of a 4.9% rate on interests paid to financing entities that are owned by foreign States, foreign Banks, and entities that invest or place capital in Mexico that comes from financial instruments issued by them and placed among the investment public, residents from countries with a Treaty to Avoid Double Taxation, is preserved through an annualy enforceable provision in the new Income Tax Law.
It is clarified that the debt derivative transactions consisting in interest SWAP futures referenced to the TIIE or to credit instruments issued by the Federal Government or the Bank of Mexico or any other one that the SAT determines through general rules, are exempt from income tax.
The reform harmonizes the provision in the Income Tax Law with the treatment established in the Treaties to Avoid Double Taxation entered into by Mexico, in the sense of applying a withholding tax on royalties to the sale of assets or rights referred to in the Federal Fiscal Code (CFF), just in those cases where such sale is conditioned to the productivity, use or ulterior arrangement from such goods or rights. In this way, the withholding over the proceeds derived from the plain sale of these types of assets and rights is eliminated.
Preferred Tax Regimes (REFIPRES)
It reintroduces the definition of the following concepts as passive income:
 The sale of immovable goods.
 Providing the use or enjoyment of goods.
 Income received on a free basis.
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It sets a term to credit the tax that would have been paid abroad for REFIPRE transactions or such tax that would have been withheld under the terms of Title V of the Income Tax Law for a period of 10 years.
Value added tax law
In the case of this Tax, it is proposed to undertake a series of adjustments aimed only to increase the tax collections.
It is suggested to eliminate the exemptions applicable to:
 The buy-sell of homes as well as to the related mortgage interests
 Educational services (school tuitions)
 Land public transportation outside the urban areas
 Public spectacles different from theater and circus, allowing the states to tax spectacles different to cinema.
With respect to the IMMEX entities, it is proposed to levy this tax on temporary imports, as well as the activities made under the automotive fiscal deposit, bonded warehouses and strategic bonded warehouses, resulting in eventual refund claim processes. Similarly it is suggested to eliminate the exemption in the case of sales between foreign residents or by a foreign resident to a maquiladora.
It is proposed to eliminate the 11% rate on the so called “border region”.
The proposal also includes the elimination of the 0% rate on hotel services and similar ones to foreign tourists, as well as the sale of gold, jewelry and gold bars, and chewing gum among others.
Special tax on production and services law
It is proposed to maintain the current tax rate on the sale and import of beverages with alcoholic content and beer. The applicable rate to beverages with alcoholic content with a level of up to 14° G.L., would be of 26.5%; for alcoholic beverages and beers with a level higher than 20° G.L., the corresponding rate would be of 53%.
It is also proposed to tax the producer and importer on the sale and import of flavored beverages; concentrates, powders, syrups, essences, flavor extracts, that when diluted, they would allow to obtain flavored beverages and syrups or concentrates to prepare flavored beverages that are sold in open containers using automated machines, electrical or mechanic, with a specific tax of $1.00 peso per liter.
These goods would be taxed even when they contain any type of added sugars.
In the case of energizing drinks, that contain added sugars, this tax would be in addition to the one that is already paid.
A definition of what should be understood as flavored beverages; concentrates, powders and syrups, essences or flavor extracts that allow obtaining or producing flavored beverages and sugars, respectively is included.
Related to the taxes that have to do with the environmental care, a tax is proposed on the sale and import of fossil fuels through specific fees by type of fuel; natural gas, propane, butane, gasoline, and aviation gas, jet fuel and other kerosene, diesel, fuel oil, petroleum and coal coke and mineral coal.
In the case of the sale and import of pest control substances, it is proposed to apply a rate that would go from 6% to 9% according to its toxicity level.
With respect to production, manufacturing and importation of cigarettes and other carved tobaccos, it would include the obligation to print a security code in each of the packets for its sale in Mexico.
Federal duties law
The reform initiative on the Federal Duties Law, with the aim to implement measures that would benefit the rational use of goods of the public domain of the Nation, sets forth modifications and in some cases proposes the abolishment of several duties in order to speed up and simplify the fulfillment of several activities or formalities to the public and the government instances themselves.
It proposes additional duties to the owners of mining concessions and claims as follows:
A special mining duty applying a 7.5% rate to the difference between certain revenues and certain deductions as per the new Income Tax Law recently proposed. The payment of the duty must be done no later than the last business day of the month of March of the following tax period. The details are as follows:
 The revenues to be included are all the ones considered by the new proposed Income Tax Law with the exception of (i) Interests, (ii) annual inflation adjustment and (iii) any cash received on loans, future capital increases, or capital increases larger than $600,000 pesos when not reported to the authorities.
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 The deductions to be included would be the same ones as per the new Income Tax Law with the exception of (i) tax depreciation, (ii) interests, (iii) annual inflation adjustment and (iv) taxes paid on the regular activity.
 In essence, it is kind of a taxable EBITDA.
There is an additional duty of 50% of the maximum fee provided by article 263 of the Federal Duties Law to the titleholders that have not undertaken proven exploration works and activities during two continuous years within the first eleven years of ownership of its concession title. The proposal fee is proposed to be raised 100% when the lack of activity is ongoing starting year 12 and later.
Over 50% of the aforementioned duties, it is proposed to set up a Mining Municipalities’ Sustainable Regional Development Fund.
An additional duty of 0.5% on the sales of gold, silver and platinum is proposed.
Universal social security
The principle is to consider Social Security as a Human Right and not only as a Labor Right.
Elevates to a constitutional range the right for the elderly to have a universal pension and the right for the workers to have an unemployment insurance by reforming article 123, section A, subsection XXIX and add to articles 4 and 73 of our Constitution. It is presented in parallel, an initiative with its respective rule legislation:
 Universal Pension Law and,
 Unemployment Insurance Law.
Additionally, it reforms, adds and abolishes provisions on the following Social Security legislation:
 Social Security Law
 Retirement Savings Systems Law
 Security and Social Services for the State Employees Law
 Workers National Housing Fund Institute and,
 Federal Labor Law
The universal pension will consist in a monthly amount of $1,092 pesos, amount that will be updated annually along with the inflation.
The obligatory contribution for the employers for the unemployment insurance will consist in the equivalent of 3% over the workers’ salary; it is not specific if the salary would be what is known in Mexico as the integrated salary.
This new system does not represent an increase in the labor and social costs of the employers or of the employees, since the universal pension would be 100% chargeable to the Federal Government and the Unemployment Insurance will be financed from the reduction on the contributions to the Housing fund, which will pass from 5% to 2%
Federal tax code
Given the structure of this piece of legislation, and that the adjustments are diverse, we will make a selection of topics relevant for its analysis:
The Tax Reform incorporates as a criterion for locating a tax domicile for individuals the one that has been provided to financial entities or savings and loans cooperative societies. The financial system entities will not allow the opening of a bank account if the user has not previously been registered in the RFC (Federal Taxpayers Registry), and furthermore such entities must provide information to the tax authorities on their account holders.
The proposal includes measures of simplification, such as the filing for the Advanced Electronic Signature which could be done through powers of attorney for representation. Also, it is proposed to create an electronic communications system between the authorities and the taxpayers denominated as tax inbox, through which the authorities will notify several documents and administrative acts and the taxpayers may file requests and other filings.
As a complement to the simplification measures, it suggests the way to eliminate the obligation to file the financial statement’s CPA opinion (Dictamen Fiscal), as well as the ones related to share disposition and the VAT refund claim statement by the CPA (declaratoria). It is expected that, in substitution to the dictamen, the taxpayer provides detailed information on all of its transactions.
It establishes the possibility for the tax authority to rule on a determination a facts or omissions, for which it will issue a provisional resolution where the possible contributions to be paid would be determined (pre-reassessment).
The proposal establishes a preferential order in the compulsory procedures when the taxpayer hinders the tax review procedures. It includes the attachment of bank deposits or insurance as an effective way to make good on the tax credits in addition to being able to freeze, its bank accounts when the taxpayer cannot located. Expedited terms for the freezing and attachment of such accounts are expected. It adds the possibility for the tax authority to attach goods owned by the
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taxpayer’s wherever they are and not only in its legal domicile.
Additionally, with the focus to facilitate the relationship with the Tax Authorities and the resolution of such tax credits, it is suggested to introduce the concept of “Conclusive Agreements’” which would allow the settlement thereof with a forgiveness of 100% of the fines. It is expected that in such agreements, the PRODECON participates as a witness. In the same manner, it proposes self-correction formats allowing the taxpayer to have access to payments in installments in more beneficial terms.
The term to refund receivable tax balances will be kept at 40 days, and given the fact that the concept of the “dictamen fiscal” (audited tax report) is eliminated, consequently the 25 business days that was allowed to taxpayers is deleted
In the area of tax documentation, it is proposed to specify that the digital internet tax invoice is the only allowed document for tax purposes and eliminates the “simplified invoice”, as well as the bank statement as a means to tax related evidence. In a related topic, it establishes the obligation to issue digital tax invoices by withholdings agents. In case that anomalies are detected in the issuance of the invoices, the authority would have the right to cancel the seal certificates or digital signatures, and in this way, avoid the issuance of tax invoices that cover probable inexistent transactions, simulated or illicit in some cases.
With regards to the tax auditing processes, it proposes to introduce an arrangement for electronic review and for the authority to enforce its right to audit through the tax inbox.
With regards to the possible repercussions for taxpayers that fail to comply, the tax authority would have the power to publish in its internet page the name and RFC of those with which it is risky to get into mercantile or commerce acts, due to the noncompliance with its tax obligations, as well as to limit the ability to enter into agreements for purchases, leases, services or public work with the Federal, Centralized and State Public Administrations, as well as the Attorney General of the Republic, of particulars that are delinquent on the filing any tax return.
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It is proposed to stipulate in the rules that the partners or shareholders, executor or representative of a succession, will be jointly liable for the contributions caused, in certain scenarios and up to the percentage of its participation.
It will not be applicable to keep the tax secret when dealing with taxpayers that are not reachable or that do not issue valid tax invoices.
Similarly, the tax authorities would be allowed to share information for objectives not relevant to taxation when the applicable international treaties allow it.
It is proposed to publish a list of taxpayers that improperly use the tax invoices. Its effect would be to establish the presumption that the transactions that they execute never existed and none of their tax invoices are effective. In the case of such taxpayers, the authorities may perform a reassessment of contributions and, if applicable, initiate a criminal process.
The initiative suggests including in the rules the possibility that the accounting and juridical professionals or their auxiliaries and the customs agents or their auxiliaries, be criminally responsible for the tax crimes when derived from an agreement they propose mechanisms related with illicit schemes or the noncompliance of tax obligations that would derive in a tax crime.
It is expected that when a corporation is declared criminally responsible for a tax crime, it will be sanctioned, with a fine, seizure, suspension, prohibition to undertake certain transactions, removal or dissolution, depending on the severity of the crime.
With regards to the criminal phenomena of the simulation of juridical acts in grievance of the tax authority, it proposes to criminally sanction whomever issue, acquire or sell tax invoices of simulated juridical acts. .
It proposes to reduce the term to challenge through the reversal recourse the terms of tax credits from 45 to 15 days. It establishes the tax inbox as the only way to file such request.
It is also suggested to include in the rules that in order to pay or guarantee the paid contributions the term would be of 10 days once the administrative alternatives are resolved (reversal, inconformity, or the procedure of controversy resolution as included in the treaties).
It establishes the maximum term of prescription would not exceed 10 years accounted from the date in which the tax credit could legally be demanded, unless such term is suspended under the expected scenarios considered for it.
Pemex’s tax regime
In the Tax Reform package presented on September 8, the Executive Power presented before Congress the Initiative for the enactment of the Income Law for Hydrocarbons, as well as modifications to the Federal Law on Budget and Tax
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Responsibility with which it is pretended to modify the current tax regime of PEMEX.
These pieces of legislation, in case of approval, are expected to be enforced in January 1 2015 and as a result, PEMEX’s regime during 2014 does not change.
Income Law for Hydrocarbons
In this new law, it is first established that PEMEX and its subsidiaries would be taxpayers of Income Tax just like any other company that does business in the country. Furthermore, introduces the concept of “State Dividend” with which it pretends to distribute the profits generated by the company to the Federation to attend the public expenses.
It establishes that PEMEX will be taxed under the basis of a lease payment for the use of the area granted in each of its shared profits agreements that enters into to perform its activities. Additionally, it will pay a variable amount, which will depend on the amount and the value of the hydrocarbons that are extracted and will take into account, as a deduction, the costs incurred to determine its profit on the agreements for which it will pay the tax.
Furthermore, it proposes a system so that PEMEX and its subsidiaries continue paying in a similar way to the current payments of duties for the income derived from the Claims for which it is the titleholder, before it achieves the migration to the format of the shared profit agreements.
If approved, PEMEX and its subsidiaries will be bound to observe what is established in the different legislations related to transparency, as well as the specific provision included in this law. On the other hand, it will be subject to the federal tax authorities audits.
Federal Law on Budget and Tax Responsibility
With the proposed changes to such Law it pretends to give budgetary independence to PEMEX and as well provide it with greater flexibility in its investment and expenses decisions without the intervention of the Tax Authority. The proposal includes major attributions for an Administration Board in the company management.
Furthermore, it provides more liberty in the acquisition of debt and eliminates the citizen bonds regime.
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