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A recent tax amendment would affect, from a reporting perspective, the current standing of a number of off-shore structures held by Mexican residents. The amendment to the Mexican Administrative Guidelines ("Miscelanea Fiscal"), in force as of July 15, 2016, is triggered by what is being discussed among countries on tax transparency and in particular, by:

  1. the conclusions reached at the 2016 London Anti-Corruption Summit where the need and mechanisms to identify the beneficial ownership of off-shore investments were discussed,
  2. the Panama Papers phenomenon, and
  3. the Mexican authorities concern of the US not participating in the exchange of tax information through the Common Reporting Standard.
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