02 / 14 / 22

Chambers & Partners Corporate Tax Guide – Back-to-Back Loans Rule in Mexico as of 2022


MEXICO CITY, MEXICO, Feburary 14th, 2022 – We are delighted to be a contributing firm to the Corporate Tax Guide with Chambers Global Practice Guides. This article will discuss how the back-to-back loans rule in force as of 1 January 2022 in Mexico could be applied by the Mexican tax authorities to effectively tackle and curb abusive tax practices, minimising the risk of creating uncertainty for taxpayers.

In order to determine whether the rules on back to back loans provided for in the Income Tax Law fulfill their function of fighting and avoiding abusive tax practices consisting of financing operations with the purpose of obtaining tax benefits, in the article we analyze the nature and scope of the general anti-avoidance rules from an international perspective, as well as the procedure that from our point of view is advisable to carry out to evaluate the operations and possible risks on the operations performed by the taxpayers.

Finally, we provide our comments and suggestions from a legal and tax perspective on the application of the rules analyzed throughout the article. To read the full article, please visit the following link https://practiceguides.chambers.com/practice-guides/corporate-tax-2022/mexico/trends-and-developments 

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Tax


Authors

Francisco Carbajal

Miguel Alonso