Qualifying Competent Authority Agreements

abril 11, 2021 Agustin

21. ←. Mexico lists tax treaties with Canada and the United States, as well as bilateral tax agreements allowing automatic exchange of information with the following jurisdictions: Austria, Canada, Hong Kong (China), Russia, South Africa, Ukraine and Usa. In addition, Mexico has double taxation conventions which, in accordance with their internal rules and in point 9 of the commentary on Article 26 of the OECD Model Tax Convention, can be interpreted in such a way that the information can be exchanged automatically (subject to confirmation of the contracting party): Australia, Bahrain, Barbados, Belgium, Brazil, Chile, China (People`s Republic), Colombia, Czech Republic, Denmark, Ecuador, Estonia, Finland, France, Germany, Greece, Hungary, India, Indonesia, Ireland, Iceland, Iceland, Japan, Italy, Italy, Japan, Italy, Norway, Japan, Iceland, Italy, Korea, Kuwait, Latvia, Lithuania, Malta, New Zealand, Netherlands, Norway, Peru, Poland, Portugal, Qatar, Romania, Singapore, Slovak Republic, Spain, Sweden, Switzerland, Turkey, United Arab Emirates Mandate Summary: under the exchange of information agreements in force under controlled jurisdiction , with the CAQ in force with the countries of jurisdiction of the inclusive framework, which meet the requirements of confidentiality, consistency and appropriate use (paragraph 9 (a) of the mandate). 22. ←. It should be noted that some competent authority agreements are not in force with the legal systems of the inclusive framework that meet the confidentiality requirements and have additional legislation: this may be due to the fact that the partner countries concerned are not in force for the first reference period or have not mentioned the jurisdiction verified in the notifications covered in Section 8 of the CBC-MCAA. Second, where the residence jurisdiction of the superior parent company has a current international agreement (multilateral or bilateral tax agreement or tax information exchange agreement providing for the automatic exchange of tax information) with the jurisdiction of a constituent entity to reside, but there is no qualified agreement between the competent authority between the two jurisdictions. This does not include circumstances in which such an international agreement does not exist. 14.

Mexico has implemented local notification obligations from the reference period as of January 1, 2016. Under Mexican primary law, the tax administration may require legal entities residing in Mexico who are subsidiaries of a foreign-based company or foreign residents with a stable establishment in Mexico to submit the ICC report «in cases where the tax authorities cannot obtain the information necessary for this declaration on the mechanisms for the exchange of information provided by the international treaties in mexico; for these effects, the subjects have a maximum period of 120 working days from the date the request is notified for the transmission of the information contained in this paragraph.» 3. Mexico is a signatory to the Multilateral Convention on Mutual Tax Assistance: amended by the 2010 Protocol (OECD/Council of Europe, 2011), which is in force for 2016 and is also a signatory to the CbC-MCAA; it has forwarded its communications in accordance with Section 8 of this agreement and intends to exchange information with all other signatories to this agreement that provide notifications.