mexican tax update new compliance obligations for immex...mexican tax update new compliance...
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Mexican Tax Update New Compliance Obligations for IMMEX July 19, 2016
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Discussion Topics
• Base Erosion and Profit Shifting (BEPS)
• Value Added Tax (IVA) Certifications
• Annex 24 and 31
• Advanced Pricing Agreement Update
• Value Added Tax Refunds
• Notice for Manufacturers & Exporters (DIEMSE)
Content
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Base Erosion and Profit Shifting (BEPS) Simón Somohano Transfer Pricing Partner
1
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The OECD/G20 BEPS Project: Background
• Work began in 2012 – Commenced following 2012 meeting of G20 Leaders – Political response to growing perception that governments lose substantial corporate
tax revenue because of base erosion and profit shifting (“BEPS”) – Involves governments of 44 countries: ◦ 34 OECD member countries, ◦ 2 OECD Accession countries, and ◦ the remaining G20 countries The OECD issued a report, “Addressing Base Erosion and Profit Shifting,” in February 2013, and an “Action Plan on Base Erosion and Profit Shifting” in July 2013 • The Action Plan: – Identifies 15 key actions needed to address BEPS – Sets deadlines to implement the actions – Identifies resources needed – Identifies the methodology to implement the actions • Final Reports were released in 2015 on – Country by Country Reporting – Transfer Pricing of Intangibles – Hybrid Mismatch Arrangements – Preventing Treaty Abuse – Digital Economy
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Action 13
New guidelines adopt 3—tiered approach
Country-by-Country Template • Key financial information on all group members on an aggregate country basis with an activity
code for each member
Master File • Key information about the group's global operations including a high-level overview of a
company’s business operations along with important information on a company’s global transfer pricing policies with respect to intangibles and financing
Local File • Information and support of the intercompany transactions that the local company engages in
with related parties
Local law will determine the language in which the documentation must be submitted. Countries are encouraged to permit filing in commonly used languages and request translation after submission
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Country-by-Country (CbC) template
• Information required by tax jurisdiction (aggregate for all entities including PEs):
ü Revenues (related, unrelated, total) ü Profit/loss before income tax ü Income tax paid (cash) ü Income tax accrued ü Stated capital ü Accumulated earnings ü Number of employees (includes independent contractors doing ordinary
operating activities) ü Tangible assets other than cash and cash equivalents
• Mexico − Article 76-A of the MITL incorporates the CbC report
• US − CbC is required by Form 8975
• Thresholds: ü CbC – MEXICO: MXN 12Bn. (~ $ 665 million) / US: $850 MILLION ü Master File – MXN 644 million (~ $36 million) ü Local File – MXN ($725,000)
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Intangibles Definition
• Separate transferability not required
• Legal protection not required but may impact value
• Accounting and legal definitions not controlling
Intangibles
Broad definition • Not a physical or financial asset • Capable of being owned or controlled for use in
commercial activities • Transferred would be compensated between unrelated
parties
Does not include • Group synergies • Market specific characteristics • Assembled workforce
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Rights to returns for the development and exploitation of intangibles • Controversial and could cause a significant change in TP outcomes • Emphasis on functions performed, assets used and risk incurred • TP outcomes in line with value creation
Identify legal owner
Identify party performing important functions
Confirm conduct of the parties
consistent with contracts
Identify the controlled transaction
related to the important functions
Determine the arm’s length price for the important functions
Design and control of
research and marketing
Management and control of
budgets
Control over
strategic decisions over
intangible development
Important decisions regarding
defense and protection
Ongoing quality control
Steps in determining intangible returns
Important functions
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Intangibles (cont’d) Returns
• Returns to intangibles are allocated to entities based on the functions they
perform, the assets used or and risks assumed.
• Mere legal ownership of the intangible entitles the legal owner to payment for
use of the intangible but does not entitle the legal owner to any intangible
returns unless the legal owner performs functions, use assets or assume risks.
• Returns are determined at the start of development activity (ex ante)
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Operational functions
Intangibles (cont’d)
DEMPE Functions
Development
Enhancement
Maintenance
Protection
Exploitation
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Important Functions Intangibles (cont’d)
• Design and control of research and marketing programs;
• Direction of and establishing priorities for creative undertakings, including determining the course of “blue-sky” research;
• Control over strategic decisions regarding intangible development programs;
• Management and control of budgets;
• Important decisions regarding defense and protection of intangibles; and
• Ongoing quality control over functions performed by independent or associated enterprises that may have a material effect on the value of the intangible.
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Valuation of functions Intangibles (cont’d)
• Important functions should be compensated with an appropriate share of the returns derived from the exploitation of intangibles
• Because it is difficult to find comparables it may be necessary to use the profit split method or valuation techniques
• The reliability of one sided methods will be reduced if the party performing important functions is considered the tested party
• Must consider options realistically available to both parties.
• One sided analysis or methods such as TNMM does not provide sufficient basis to evaluate the transaction.
• Guidance sets a high bar for use of CUP
• Profit split and valuation techniques are preferred methods
• Profit split guidance in 2016/2017
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Value Added Tax (IVA) Certifications Jorge Ferreira Int´l Trade & Customs Consultor
2
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FTGR 7.1.2.Requirements that the Companies need to qualify, in order to obtain VAT IEPS Certification for
modality A
FTGR 7.1.3.Requirements that the Companies need to qualify, in order to obtain VAT IEPS Certification for
modality AA and AAA
FTGR 7.2.1. Obligations/maintenance VAT IEPS
Certification
FTGR 7.2.2. Cause of requirement for VAT IEPS Certification
FTGR 7.1.1 General requirements for obtaining the VAT IEPS Certification 1
2 3 4
5
Grants 100% credit to the VAT and IEPS duties for
temporarily imported goods.
VAT IEPS Certifications Foreign Trade General Rules
FTGR 7.2.2.Cause of requirement for VAT IEPS Certification 5
FTGR 7.2.3. VAT IEPS Certification Renewal 6 FTGR 7.2.4. Cause for cancellation for VAT IEPS
Certification 7
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• 7.3.1. FTGR:
1. Refundable VAT duty that corresponds:
• A: 20 days
• AA: 15 days
• AAA: 10 days
• 2. Automatic registry within the importer’s license for the paragraph A, of the Annex 10 and 11
• 3. If the Authority detects irregularities that cause suspension of your importer’s registry, it will notify you so you can correct such irregularities.
• 4. Excempts the obligation of presenting value manifestation and calculation sheet for temporarily imports.
• 5. It will grant a period of 36 months for the temporarily imported goods.
• 6. Grants the benefit of not requiring authorization for a rectification within the first three months (AA).
• 7. They have the benefit of requesting customs clearence for import and export operations.
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General Benefits VAT IEPS Certification
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• FTGR 7.1.1, 7.1.2, 7.1.3, 7.2.1. (A, AA, AAA):
• Be updated with your fiscal obligations.
• That your personnel is registered in IMSS.
• Have all your establishments registered before SAT.
• Have an e-mail account registered before SAT.
• Have an active importer’s registry.
• Allow access at all times to SAT authorities.
• Have a legal document that proves that you are the owner/renter of the Company’s premises, for at least one year.
• Make sure that the Company doesn’t have a law sue against their partners, legal representative, or members of the Company’s administration in the last three years.
• Good control of materials and equipments.
• Good control of the Annex 31.
• Have the proper infrastructure for the Company’s services/production.
Obligations VAT IEPS Certification
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• FTGR 7.1.1, 7.1.2, 7.1.3, 7.2.1. (A, AA, AAA):
• Prove that you return abroad at least 60% of value of the temporarily imported goods within the last 12 months.
• Prove that you return abroad at least 80% of value of the temporarily imported goods within the last 12 months (Companies that export products such as metals and textiles).
• The use of Single Virtual Pedimento for operations within Mexico (consolidated virtual transfers, weekly or monthly).
• Monthly report to the Authority through Single Window within the firs days of each month, if any modifications are made with the Company administration, partners, and legal representatives.
• Every three months you will have to report all your supplier’s from which you obtain the raw materials.
• In AA modality you will need to prove that at least 40% of your mexican suppliers have a positive opinión from SAT Authority.
• In AAA modality you will need to prove that at least 70% of your mexican suppliers have a positive opinión from SAT Authority.
Obligations VAT IEPS Certification
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VAT IEPS Certification
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What happens if you don´t comply with the Foreign Trade General Rules obligations?
7.1.1, 7.1.2, 7.1.3, 7.2.1 The following actions could lead up to a VAT and IEPS certification requirement. If you don´t provide the necessary information that the Authority requested in such requirement it may lead to a cancellation of your VAT IEPS Certification.
Penalties and sanctions
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Annex 24 Annex 31 3
Jorge Ferreira Int´l Trade & Customs Consultor
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Inventory Control System
Annex 24 Companies with an IMMEX program have the obligation to manage and
carry out an Inventory Control System.
According to Article 59, fraction I of the Customs Law
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Annex 24
Benefits
1. Have a correct order and management of the imported goods.
2. The Company will be able to apply in the following modalities:
• Industrial companies• Service companies• Shelter companies• Usage of other company´s facilities (terciarización)
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Obligations Annex 24 (cont’d)
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To have a system that registers the
discharges of the imported goods,
as well as exportations.
Apply proper controls to the registry of the
imported goods, as well as
exportations.
Keep track of the temporarily
imported goods, making sure that
they are returned before
their time expires.
To be able to generate the
following reports (SAT Audit):
• Import • Export • BOM • Discharges • Open Balance
It is an obligation to count with an automated Inventory Control System, that allows the compliance of the following requirements
and dispositions established within the Customs Law, Foreign Trade General Rules, and the IMMEX Decree.
1 4 3 2
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Annex 24 (cont’d)
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Consequences for
noncompliance with the
obligations
Article 185-B of the Customs Law
When the Company does not comply with an automated and updated Inventory Control System, this would cause a tax penalty of
$10,000 to a $20,000, this will depend on the Authority´s criteria.
Articles 176 Fraction X, 177 Fraction VIII, and 178 Fraction IX of
the Customs Law. When the Company does not comply with paying the amount from
import duties, this would cause a tax penalty between (138 and 150% of the value of the goods), this will depend on the Authority
´s criteria.
Article 178 Fraction III of the Customs Law When the Company imports prohibited goods, this would cause a tax penalty between (70% and 100% of the value of the goods) ,
this will depend on the Authority´s criteria.
Penalties and sanctions
1
2
3
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------Companies with an IMMEX program, have the obligation to comply with the
16% of VAT payment of temporary imported goods since January 1st, 2015.
Companies certified in VAT and IEPS, have the exemption of this payment, which have to comply with Annex 31.
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Annex 31
According to Article 28 of the mexican VAT Law
Annex 31
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Annex 31
Have a correct order and management of:
• Temporarily imported goods• Exported goods (returns)• Expired goods• Definitive goods (change of regime).
Benefits
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Companies with VAT-IEPS
Certificate are obligated to present their
Initial Inventory Report (historical Open Balance).
Companies with VAT-IEPS
Certificate are obligated to present the
Discharge reports that affect their Initial Inventory
Report.
Articles 28-A from the Customs Law and the Article 15-A from the IEPS Law
Annex 31 is the system where SAT will control and watch the temporary imported
balances that were not returned on a timely matter.
1 2
Annex 31 (cont’d)
FTGR: 7.1.1, 7.1.2, 7.1.3:
Obligations
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Annex 31 (cont’d)
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There are no penalties in case of non-compliance with this obligation, but these are sanctions that
could be applied:
7.2.4. FTGR: The following actions could lead up to a VAT and IEPS certification cancellation:
1. Non-compliance with the obligation of transmitting on time and formal manner the Initial Inventory and Discharge Reports.
2. Companies with an IMMEX program that don’t prove the following, within a timely matter: • That their merchandise was temporarily imported • Returned abroad • Transferred • Where destined to another customs’ regime (definitive)
Penalties and sanctions
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Advanced Pricing Agreement Update Simón Somohano Transfer Pricing, Partner
4
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Maquiladora (IMMEX)
Inventory
Management and Control
Foreign Principal
MEX 1
3
PE M&E
2
Company ABC
PE
Background Maquiladoras Advanced Pricing Agreements
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1995 • Enforcement of PE &
Double Taxation regulations
• TP compliance/PE protection: Safe Harbor (5% ROA) or APA
1999-2000 / 2000-2003 • Mutual agreement US-
Mexico • TP compliance/PE
protection: APA or Safe Harbor (6.9% ROA or 6.5% Cost Plus)
2003-2013 • TP compliance/PE protection:
• Safe Harbor (6.9% ROA or 6.5% Cost Plus)
• Cost-Plus + 1% / 1.5% ROA M&E
• Cost-Plus + ROA M&E • APA
• Presidential decrees: October 2003 & November 2007
2014 - ? • TP compliance/PE
protection: • Safe Harbor (6.9% ROA
or 6.5% Cost Plus) • APA (New
methodology) • New definition of
Maquiladora (MITL)
Maquiladora
Maquiladoras Advanced Pricing Agreements
Transfer Pricing compliance/PE protection stages
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Maquiladora operation structure according to definition of MITL
Maquiladora (IMMEX)
Maquila service income: Cost & expenses plus profit margin
Foreign Principal Foreign Principal
Mexico
Finished goods Total income of its “productive activity” of maquila operation.
Raw material Foreign & local M&E: at least
30% on consignment
Maquiladoras Advanced Pricing Agreements
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PE protection and Transfer Pricing compliance options effective 2014
Article 182 of New MITL
Transfer Pricing Study (1) Return without foreign owned
assets + 1% of the M&E (2) Return considering foreign
owned M&E.
Article 182
Safe Harbor (Minimum Taxable Income) (1) 6.9% over Operating Assets
(2) 6.5% over Cost and Expenses
Advance Pricing Agreement (APA)
Methodology yet to be determined by SAT.
The 2014 Tax Reform eliminates the Tranfer Pricing Study option that has been largely used by Maquiladoras for the past 10 years.
Maquiladoras Advanced Pricing Agreements
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Background Maquiladoras Advanced Pricing Agreements
• In force starting January 1st 2014.
• Definition of “maquila operation” within the MITL (Article 181):
ü Total income of its productive activity, should be related to the maquila operation.
ü The materials imported on a temporary basis would need to be returned abroad
including virtual exports.
ü Nonresident would have to provide M&E for maquila operations
ü A minimum of 30% is required and the M&E should not been owned before by the
maquiladora or a Mexican related party.
ü No M&E owned by a Mexican related party can be used.
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Methodology Maquiladoras Advanced Pricing Agreements
• The SAT is proposing an “expedite” methodology in order to resolve maquiladoras APAs
• This methodology includes the following:
ü A differentiation between labor intensive maquiladoras and asset intensive maquiladoras
ü Asset intensity is determined by Maquiladora total assets relative to labor (payroll + operating expenses)
ü Labor Intensive Maquiladoras – A return on the maquiladora costs (Cost Plus) + a return on assets on foreign owned assets (M&E + Inventories)
ü Asset Intensive Maquiladoras – An asset-adjusted return on maquiladoras costs (Adjusted Cost Plus) + a return on assets on foreign owned assets (M&E + Inventories)
ü Adjusted Cost Plus varies according to industries – Automotive, Electric & Electronics and Other (Metal, Plastics, Medical Devices, Aerospace, Furniture, Textile, etc.)
ü Net Foreign Exchange Gains/Losses are subtracted/added from maquila revenue (neutralization of FX effects)
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Methodology (cont’d)
Maquiladoras Advanced Pricing Agreements
• The final “expedite” methodology will be published as part of the Fourth Miscellaneous Tax Rules
• Ongoing discussions include the National Maquiladoras Association (INDEX) and the US IRS
• Maquiladoras may apply a different methodology but the may expect longer time to conclude the APAs
• Conversion into a Bilateral APA is possible
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Value Added Tax Refunds Hector Vega Tax Partner
5
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Automatic refund
New VAT refund process
Deposit within 5 business days (Misc. Resol. 2.3.17)
No greater than 1,000,000 Mexican Pesos
Non applicable for taxpayers who:
a) Have no access to “buzón tributario” (it’s important for a fast and timely communication between SAT-taxpayer)
b) Have not sent their electronic accounting information (except Constitutional Relief [Amparo])
c) Have not been able to issue their electronic invoices (canceled certificate)
d) Have suppliers who are not able to issue electronic invoices (canceled certificate)
e) Have tax credits in process, tax due in courts (without Guarantee), the SAT has not been able to find, have been accused of a specific tax crime, or when the tax payer is characterized by the SAT as a tax payers that issues invoices for nonexistent operations.
f) Same limitations from previous bullet point, but in regards to the suppliers of the taxpayer
The SAT will analyze the refund request in accordance to an “Automated risk model” in order to approve or deny the automatic refund process in accordance to this rule
If the process is denied (deposit not received within 5 business days), the Taxpayer will have the opportunity to request the refund by the normal process.
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VAT refund process update
The SAT continues with a policy of tax symmetry
Partial refunds
Problems with suppliers (Outsourcing, construction, Individual services)
Transportation (Exportation and not subject to VAT)
VAT on import vouchers
Outsourcing (aggressive positions) SAT denied deduction and paid VAT
The SAT is not complying with the deadline according to “VAT Certification benefits”
Off setting process (same situation)
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Outsourcing update
Recent court cases have established that if the outsourcing company does not comply with certain labor and fiscal requirements, then the employees must be considered as employees of the maquiladora company in which they perform their personal subordinate services. The requirements are as follows:
a) The outsourcing employees may not have the total amount of activities, equal or similar in it’s whole, that are being developed in the working center.
b) Their activities must be justified by its specialized nature.
c) Their activities must not include the same or similar tasks as those activities that are being completed by the rest of the employees of the contracting company.
One of the consequence could be that the expense paid may be considered as non deductible and that the VAT may not be refundable.
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Notice for Manufacturers & Exporters (DIEMSE) Hector Vega Tax Partner
6
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DIEMSE (Informative declaration/return)
Obligated Taxpayers
Maquiladoras applying Safe Harbor method or APA
Shelter Maquiladoras
If DIEMSE is filed on time there is no need to file:
Safe Harbor written notice before SAT
Written notice of addition deduction for Maquiladoras (deduction of the employees exempt income)
In this declaration the Maquiladora will support that 30% of its M&E is owned by the foreign Company.
Deadline
FY 2014.- April 15, 2016
FY 2015.- September, 2016
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Contacts
Simón Somohano Transfer Pricing Partner [email protected] +52 (664) 622 7872 Héctor Vega Tax & Legal Partner [email protected] +52 (664) 6227821 Jorge Ferreira Int´l Trade & Customs Consultor [email protected] +52 (664) 622 7894 www.deloitte.com/mx
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