Mexico's substance-over-form dilemma

Resource Information

The item Mexico's substance-over-form dilemma represents a specific, individual, material embodiment of a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation.
This item is available to borrow from 1 library branch.

Summary: The substance-over-form doctrine embodied in article 213, paragraphs 19-22 of the Mexican Income Tax Law is generally used by the Mexican tax authorities as a practical tool to prevent erosion of the tax base. Over the course of 2011, however, the tax authorities appear to have become more inclined to use the doctrine to strengthen their audit and assessment powers, thus going beyond the legislative intent of the provision and no longer confining their application of the doctrine to transactions involving tax havens and transactions with foreign related parties

Work

Summary: The substance-over-form doctrine embodied in article 213, paragraphs 19-22 of the Mexican Income Tax Law is generally used by the Mexican tax authorities as a practical tool to prevent erosion of the tax base. Over the course of 2011, however, the tax authorities appear to have become more inclined to use the doctrine to strengthen their audit and assessment powers, thus going beyond the legislative intent of the provision and no longer confining their application of the doctrine to transactions involving tax havens and transactions with foreign related parties