Decrees for Declaration of the Special Economic Zones of Lázaro Cárdenas-La Unión; Puerto Chiapas and Coatzacoalcos

Similar documents
This decree enters into force on 19 January 2017 and will remain in force for the six months following this date.

General rules for the application of the Technological Research and Development tax incentive

Tax Alert 01/2014. Presidential Decree The decree, which applies as from 1 January 2014 (unless otherwise noted), includes the following measures:

Decree Enacting the Financial Technology Institutions Law ( Fintech Law )

Executive summary. Income Tax Law (LISR) Legal entities. A summary of the salient modifications is as follows:

RBC Capital Markets Transportation and Industrials Conference

TAX REFORM 2017 MEXICO

Profile. Our Mission: Site Selection - Shelter Administrative Services - Industrial Real Estate

June 2011 Deloitte Mexico. Investment Environment in Mexico.

skiron\roadshow\presentación Roadshow Script 2.ppt

SETTING UP BUSINESS IN MEXICO

Public Sector Pension and other Reform Experiences from Mexico

DFK - González y Asociados, S.C. Audit - Tax Controllership - Consulting

Clients Bulletin. BéndiksenLaw* Members of Law Offices International MEXICO S NEW TRANSFER PRICING ADJUSTMENTS RULES.

IMMEX Challenges, Facing Unconstitutional Tax Reform.

Cautionary Information

Fideicomiso Irrevocable No. F/1596 (Deutsche Bank México, S. A. Institución de Banca Múltiple, División Fiduciaria) and Subsidiary

February, Q17 Quarterly Results Update Fideicomiso F/2157 FMTY14

The Exporting Maquila and Manufacturing Industry. Perspectives- Achievements - Agenda March 2009

Independent Auditor s Report

Generating results. Mexico

MOORE STEPHENS. Moore Stephens México

2007 BB&T Transportation Conference

Goldman Sachs Global Industrials Conference

CEO Comments. Dear Investors:

Fibra Uno Announces Income of Ps. 198 million in 1Q12

January 25, Jim Young, President & CEO

To November, mortgages grew by 5.8%

Grupo Posadas, S.A.B. de C.V. & Subsidiaries Mexico City, October 25, 2018.

Perspectives on North American Pipeline Infrastructure Opportunities

Manufacturing. Manufacturing sector. Nordic Investment in Mexico

The National Infrastructure Programme is the most ambitious yet: if executed, it will impact positively on the economy

Assisting: Steve Andersen, Cristina Castaneda, Cecilia Azar, Bob Lutz and Jim Nelson

different STORY ANNUAL REPORT 2003

PRESENTATION TO INVESTORS DECEMBER 2014

Third Quarter 2015 Financial Results

Mexican Tax Authorities publish format for filing 2014 DIEMSE

FOREIGN TRADE AND INVESTMENT IN CUBA PORTFOLIO OF OPPORTUNITIES

1 st Quarter. Highlights:

BB&T Transportation Services Conference February 15, 2012

Mexico substantially modifies transfer pricing adjustment rules. Global Transfer Pricing Alert

INFORMATION CONCERNING THE CIRCULATING ESTATE TRUST CERTIFICATES OR CBFIs

Maxcom Telecomunicaciones, S.A.B de C.V.

Investment Project Fiduciary Securitization Certificates (CERPIS)

J.P. Morgan Transportation Conference March 13, 2012

Subnational Revenue Mobilization in Mexico

Setting. higher. goals

{Update.} Mexico Tax, Labor, and Legal Update with the United States-Mexico Chamber of Commerce and Miller Canfield.

PARAGUAY S MAQUILADORA SYSTEM

Mexican Income Tax Law Articles , referring to transfer pricing in maquila operations

Colombia VAT. Types of indirect taxes (VAT/GST and other indirect taxes) General

Mexico Regional Sectoral Outlook

ANNUAL SUSTAINABILITY REPORT 2015

Comisión Federal de Electricidad (A Decentralized Public Entity of the Federal Government)

Maquiladora Regime in Paraguay

MEXICO: Urban Transport Transformation Project (UTTP) Restructuring Paper May 2016 Responses to comments from the UK and Germany

CEO Comments. Dear Investors:

Empresas ICA, S.A.B. de C.V. (the Company or EMICA ) which we refer to, collectively, as the Existing Notes.

Copyright. Maria F. de la Fuente Gutierrez de Quevedo

Corporación Inmobiliaria Vesta S.A.B. de C.V. 1Q17

Doing Business in Mexico

(In millions pesos as of March 31, 2000) Accumulated

Mexico. Investment basics

North American Development Bank

and of the Audit Committee

GRUPO SENDA AUTOTRANSPORTE, S.A. DE C.V. ANNOUNCES FOURTH QUARTER AND TWELVE MONTH RESULTS AS OF DECEMBER 31, 2008

Quarterly Report - First Quarter 2013

APPENDIX C - DRY VAN ACCESSORIAL CHARGES

Grupo Posadas, S.A.B. de C.V. & Subsidiaries Mexico City, October 22, 2015

Regional Economic Report July September 2015

PRESENTATION TO INVESTORS AUGUST 2015

Highlights on Maquiladora Topics

Investor Presentation

Grupo Financiero BBVA Bancomer, S.A. de C.V. and Subsidiaries (Subsidiary of Banco Bilbao Vizcaya Argentaria, S.A.)

14.01 TRANSFER PRICING IN MEXICO

ABC Aerolíneas, S. A. de C. V., and Subsidiaries

VINTE Viviendas Integrales S.A.B. de C.V. Some of the most important aspects on which the rating is based are:

Index of Local Democracy (CILD)

THIRD QUARTER 2015 EARNINGS RELEASE

Consolidated Financial Statements

MEXICO. WHEREVER you ARE, it s HIGHLY. PROBABLE that SOMETHING AROUND you has BEEN MADE in

Altos Hornos de México, S. A. B. de C. V. and Subsidiaries. (A Subsidiary of Grupo Acerero del Norte, S. A. de C. V.)

Sustainable Bond VINTE Viviendas Integrales S.A.B. de C.V. International Capital Market Association (ICMA). 2

Global Tax Alert. Mexico s President issues Decree granting tax incentives to maquiladoras. Executive summary. News from Americas Tax Center

Fibra Uno Quarterly Earnings Presentation 3Q17

Doing. Business in Mexico COMPARING REGULATION IN THE 31 STATES AND MEXICO CITY. Public Disclosure Authorized. Public Disclosure Authorized

TAX ALERT. Royal Decree-Law 3/2016, of December 2, which adopted the tax measures to consolidate public finance and other urgent social measures

Management Report to the Board of Directors

Strategic Bonded Warehouse. Added-Value Investment.

Regional Economic Report October December 2014

Colors for Charts and Graphs JUNE 2016

Annual Report 2001 EMBOTELLADORAS

International Tax Israel Highlights 2018

2Q13 EARNINGS RELEASE

International Tax Brazil Highlights 2019

Key amendments to PRC interim Value Added Tax (VAT) regulations

Driving change. Achieving results.

Serbia. Tax&Legal Highlights May International taxation

Economic Border Zone A strategic analysis of the tax Reform Initiative for the Northern Border Region. Tax

F/2061 Irrevocable Trust FHipo and Subsidiaries (Banco Invex, S.A., Institución de Banca Múltiple Grupo Financiero Invex, Fiduciario)

Transcription:

Decrees for Declaration of the Special Economic Zones of Lázaro Cárdenas-La Unión; Puerto Chiapas and Coatzacoalcos On September 29th, 2017, the decrees of reference were published in the Federal Official Gazette and entered into force on September 30th, 2017. In this sense, Integral Administrators and Investors that carry out Economic Productive Activities in the mentioned zones, are granted with a number of tax benefits and incentives, according to the following: Income Tax During the first ten fiscal years as of the date in which the Authorization to carry out activities in the Special Economic Zone is granted, Integral Administrators and Investors will have a 100% reduction of their income tax, for the income earned within the Special Economic Zone; and for the following five years after the tenth fiscal year mentioned, a reduction of 50%. Taxpayers who apply the income tax reduction referred to in this Decree must maintain at least the same number of insured employees registered under the obligatory regime before the Mexican social security authorities (IMSS) in all the fiscal years in which they apply the benefit, and these workers must render their services exclusively in the establishments, agencies, branches or any place of business of the taxpayers that is located in the Special Economic Zone. Mexican residents that establish in the Special Economic Zone may credit against the income tax, the income tax that they have paid abroad, applying to such tax, a discount similar to the one received corresponding to their activities in the Zones. These benefits will not be applicable to the optional integration tax regime and, in the case of the Maquila Regime, taxpayers will

be able to apply the benefits of this Decree, without them being added to the benefits established in the Mexican Income Tax Law (i.e., benefits derived from operating under the maquiladora regime). The taxpayers of the Special Economic Zones would be able to apply a tax incentive consisting of an additional deduction applicable against the income generated in the Special Economic Zones, equivalent to 25% of the expense actually incurred for the training received by each of their employees. Taxpayers who have an establishment, agency, branch or any place of business in the Special Economic Zones are granted with a tax credit during the first ten fiscal years in which they carry out activities within said Zones, applicable against the income tax equivalent to 50% of the employer s contribution of the insurance for illnesses and maternity, and equivalent to 25% of said contribution during the following five years. When the tax credit is greater than the income tax in a given fiscal year, taxpayers may file a refund request or may offset such balance against other taxes. Rights Integral Administrators are exempt from the payment of rights for the use or enjoyment of assets of the public domain of the Federation. Value Added Tax The sale of goods, the provision of services and the granting of the temporary use or enjoyment of tangible assets by taxpayers located outside the Zones, which are provided or granted to the Integral Administrator or Investors to be used or taken advantage of within the Zones and that are directly related to the construction, management or maintenance of the Zones or for carrying out Economic Productive Activities established in the Special Economic Zones Law, will be subject to a 0% value added tax (VAT) rate. The introduction to the Special Economic Zones of goods coming from abroad; the acquisition of intangible assets by residents of the Zone and sold by non-mexican residents; the temporary use or enjoyment of intangible assets in the Zone provided by nonresidents of the country; the use or temporary enjoyment of tangible assets in the Zone which physical delivery occurred outside of Mexico, and the use of services in the Zone when rendered by nonresidents in the country, would not be considered as an importation for purposes of the VAT, so they will not be subject to the payment of such tax. In the event that the Integral Administrator or the Investors introduce to the Zone goods that were acquired outside of the Zone and for which they were charged with the corresponding VAT, they will be able to recover such tax by requesting its refund before the Mexican tax authorities, provided that they had only carried out acts or activities within the Special Economic Zone, or by crediting it, when they perform, also, acts or activities in establishments located in the rest of the country. The extraction of goods of the Zone to be introduced to the rest of Mexico, would be subject to VAT. The extraction of goods from the Zone to be exported or to be returned abroad, will not have VAT consequences. In the case of the extraction of goods from the Special Economic Zone to be introduced to the rest of the country, it is established that: i) when the introduction occurs as a result of a sale, the tax will be caused only for the introduction and not for the sale; ii) the tax basis will be the one established by the VAT Law for the sale, when there is one and, when there is no sale, it will be the price of the good that corresponds to the prices or amounts of considerations that would have been used with or between independent parties in comparable operations in terms of the Mexican Income Tax Law; iii) the payment of the tax will be made at the time the goods are presented for their introduction to the rest of Mexico, and iv) the credit of the tax paid for the introduction of goods to the rest of the country will be made in terms of VAT Law, in a similar way to the tax paid on the importation. The extraction of goods from a Special Economic Zone to be introduced to the rest of Mexico may be carried out for purposes other than sale, such as the extraction of goods for personal use, machinery and equipment to be repaired or maintained, tangible goods leased to Integral Administrators and Investors of the Zone and goods to be destined to the temporary importation regime in the Maquila or export programs. It is established that in these cases no VAT would be triggered at time of introduction to the rest of Mexico. Transactions carried out within the Zone would not be considered as taxable for VAT purposes, nor will those who make them would be considered as taxpayers of it, in respect of such transactions. Acts or activities carried out by an Integral Administrator or an Investor with another Integral Administrator or Investor, residing in a Special Economic Zone, will be deemed not subject to VAT, as long as the control requirements that ensure that such acts or activities will be used within a Special Economic Zone are fulfilled. The extraction of goods from a Special Economic Zone made by an Integral Administrator or an Investor to be introduced by them to an establishment of their property located in another Special Economic Zone, will not be subject to VAT, as long as certain control measures are fulfilled. Customs Regime The Integral Administrator and Investors that introduce goods into the Zone under the corresponding customs regime would be granted with the following tax benefits: reduction in the payment of Customs Processing Fee pursuant to the Federal Fees Law; the payment of import duties will be triggered in the extraction of goods from the Zone; and it will be possible to choose the lowest import duty rate between the rate applicable to raw materials and the one applicable to the goods after having been processed, transformed or repaired within the zone. Various administrative benefits are granted,

such as the possibility of introducing goods into the Zone through consolidated customs declarations ( pedimentos ); transfer of goods between Investors located in the same or different Zone; temporary extraction of machinery and equipment for repair or maintenance; carry out the introduction of goods without complying with the non tariff regulations and restrictions, nor the Mexican Official Norms determined by the Ministry of Economy, among others. Since the Federal Law on Special Economic Zones does not establish any treatment for said Zones in the field of excise tax on production and services, said tax must be applied in accordance with the applicable Law. Contact: Tax Benefits and Incentives Fernando Silis fesilis@deloittemx.com Tel. +5255 5080 6000 www.deloitte.com/mx www.deloitte.com/mx/tax tax@hand App Download our tax@hand app. Available on: www.taxathand.com For: IOS, Android and Blackberry Rules are laid down to neutralize the customs regime in the field of excise tax, consisting of: 01. The introduction into Mexico of the goods under said customs regime will have the character of permanent importation; 02. Customs operations resulting from the transfer of goods between Investors shall not be considered as exportation or importation, as appropriate; 03. That the extraction of goods from the Special Economic Zone for introduction into the rest of Mexico will not trigger the excise tax on the permanent importation for customs purposes; and 04. Operations covered by documents proving the introduction of the goods to the Special Economic Zone shall not be considered as exports. Deloitte Themis Download our widget www.deloittethemis.com * Available only for Windows 8

Aguascalientes Universidad 1001, piso 12-1 Bosques del Prado 20127 Aguascalientes, Ags. Tel: +52 (449) 910 8600 Fax: +52 (449) 910 8601 Mazatlán Avenida Camarón Sábalo 133 Fraccionamiento Lomas de Mazatlán 82110 Mazatlán, Sin. Tel: +52 (669) 989 2100 Fax: +52 (669) 989 2120 Puebla Edificio Deloitte, Vía Atlixcayotl 5506, piso 5 Zona Angelópolis 72190 Puebla, Pue. Tel: +52 (222) 303 1000 Fax: +52 (222) 303 1001 Cancún Avenida Bonampak SM 6, M 1, lote 1, piso 1077500 Cancún, Q. Roo Tel: +52 (998) 872 9230 Fax: +52 (998) 892 3677 Chihuahua Av. Valle Escondido 5500 Fracc. Des. El Saucito E-2, piso 1, 31125 Chihuahua, Chih. Tel: +52 (614) 180 1100 Fax: +52 (614) 180 1110 Ciudad Juárez Baudelio Pelayo No. 8450 Parque Industrial Antonio J. Bermúdez 32400 Ciudad Juárez, Chih. Tel: +52 (656) 688 6500 Fax: +52 (656) 688 6536 Culiacán Calz. Insurgentes 847 Sur, Local 103 Colonia Centro Sinaloa 80128 Culiacán, Sin. Tel: +52 (667) 761 4339 Fax: +52 (667) 761 4338 Guadalajara Avenida Américas 1685, piso 10 Colonia Jardines Providencia 44638 Guadalajara, Jal. Tel: +52 (33) 3669 0404 Fax: +52 (33) 3669 0469 Hermosillo Blvd. Eusebio Francisco Kino No. 315 Piso 8, Suite 804, Colonia Lomas Pitic 83010 Hermosillo, Son. Tel: +52 (662) 109 1400 Fax: +52 (662) 109 1414 León Paseo de los Insurgentes 303, piso 1 Colonia Los Paraísos 37320 León, Gto. Tel: +52 (477) 214 1400 Fax: +52 (477) 214 1405 Mérida Calle 56 B 485 Prol. Montejo Piso 2 Colonia Itzimna 97100 Mérida, Yuc. Tel: +52 (999) 920 7916 Fax: +52 (999) 927 2895 Mexicali Calzada Francisco López Montejano 1342 Piso 7 Torre Sur Fraccionamiento Esteban Cantú 21320 Mexicali, B.C. Tel: +52 (686) 905 5200 Fax: +52 (686) 905 5232 México, D.F. Paseo de la Reforma 505, piso 28 Colonia Cuauhtémoc 06500 México, D.F. Tel: +52 (55) 5080 6000 Fax: +52 (55) 5080 6001 Monclova Blvd. Ejército Nacional 505 Colonia Los Pinos 25720 Monclova, Coah. Tel: +52 (866) 635 0075 Fax: +52 (866) 635 1761 Monterrey Av. Juárez 1102, piso 40 Centro 64000 Monterrey, N.L. Tel: +52 (81) 8133 7300 Fax: +52 (81) 8133 7383 Carr. Nacional 85, 5000, local S-6 Colonia La Rioja 64988, Monterrey, N.L. Tel. +52 (631) 320 1673 Fax: +52 (631) 320 1673 Nogales Apartado Postal 384-2 Sucursal de Correos A 84081 Nogales, Son. Tel: +52 (631) 320 1673 Fax: +52 (631) 320 1673 Querétaro Avenida Tecnológico 100-901 Colonia San Ángel 76030 Querétaro, Qro. Tel: +52 (442) 238 2900 Fax: +52 (442) 238 2975, 238 2968 Reynosa Carr. Monterrey-Reynosa 210-B, PA Fracc. Portal San Miguel 88730 Reynosa, Tamps. Tel: + 52 (899) 921 2460 Fax: +52 (899) 921 2462 San Luis Potosí Av. Salvador Nava Martínez 3125, 3-A Fracc. Colinas del Parque 78294 San Luis Potosí, S.L.P. Tel: +52 (444) 1025300 Fax: +52 (444) 1025301 Tijuana Misión de San Javier 10643, Piso 8 Zona Urbana Río Tijuana. Tijuana B.C., 22010 Tel: +52 (664) 622 7878 Fax: +52 (664) 681 7813 Torreón Independencia 1819-B Oriente Colonia San Isidro 27100 Torreón, Coah. Tel: +52 (871) 747 4400 Fax: +52 (871) 747 4409

Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited, a UK private company limited by guarantee and its network of member firms, each of which is a unique and independent legal entity. Please consult our website at www. deloitte.com/mx/conozcanos for a detailed description of the legal structure of Deloitte Touche Tohmatsu Limited and its member firms. Deloitte renders professional services in the areas of audit, taxes and legal services, consulting and advisory, to public and private clients from different industries. With a global network of member firms in over 150 countries, Deloitte offers world-class capacities and high quality service to its clients, providing the experience necessary to deal with the most complex business challenges. The more than 225,000 employees of Deloitte are committed to achieving significant impacts in their communities. As utilized in this document, Deloitte means Galaz, Yamazaki, Ruiz Urquiza, S.C., which has the exclusive legal right to become involved in, and limits its business to, the provision of services of audit, tax consulting, advisory and other professional services in Mexico, under the name Deloitte. This publication contains only general information and neither Deloitte Touche Tohmatsu Limited, its member firms, nor any of their respective affiliates (collectively the Deloitte Network ), render advice or services through this publication. Before taking any decision or measure which may affect your finances or business, you should consult a qualified professional adviser. No entity of the Deloitte Network will assume responsibility for losses suffered by any person or entity that consults this publication. 2017 Galaz, Yamazaki, Ruiz Urquiza, S.C.