LEGAL AND FINANCIAL IMPACT OF THE CORPORATE TAX RATE TO SINGLE IN THE AGREEMENTS TO AVOID DOUBLE CHARACTERISTICS WITH MEXICO, IMPACTO LEGAL Y FINANCIERO DEL IMPUESTO EMPRESARIAL A TASA UNICA EN LOS CONVENIOS PARA EVITAR LA DOBLE TRIBUTACION CON MEXICO

Rigoberto Reyes Altamirano

Revista Internacional Administracion & Finanzas, 2014, vol. 7, issue 3, 91-112

Abstract: This work analyses the impact of the single rate business tax has had, since its creation in 2008. The objective of the 2008 law was to avoid double taxation in Mexico. that Mexico had signed before the mentioned year, as well as those who were modified and entered into force, following its implementation in the country; the existential elements of the single rate business tax to determine whether it constitutes a tax identical or similar to the content of agreements to avoid double taxation, arriving at the conclusion that to be considered a "gross receipts tax" and on a taxable basis on the "tax benefits", is not regarded as such by the tax authorities of the United States of America; the problematic fiscal and financial that can be generated, if the concerned country, does not accept how creditable tax designated above, under the percentage representing that country in foreign direct investment to our country, as well as the legal nature to the comments when the Model Convention to avoid double taxation, as an authentic interpretation of source or as an interpretative declaration of the Organization for cooperation and development.

Keywords: CEDT; Comments on MOCDE; Tax; Rate Business Tax; México; MOCDE; USA (search for similar items in EconPapers)
JEL-codes: K20 K33 K34 (search for similar items in EconPapers)
Date: 2014
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