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Currently there are few organizations whose total sale, acquisitions or investment transactions are carried out in one country only, and this forces them to search for specialized advisors who besides maintaining an excellent practice in the domestic tax field, can also provide advisory to those involved in the decision-making regarding the consequences that an international tax environment may produce on the business decisions made and business models adopted.
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Furthermore, this interchange has not only been generated at a purely business or financial level, but also at the human capital level which also requires an adequate equity and tax advisory for those individuals who change their residence and nationality or make investments in different tax jurisdictions.
Baker Tilly México counts on international tax specialized professionals with experience in providing advisory to multinational companies both public and private.
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Among the services we render are the following:
Inbound Transactions Advisory
This kind of advisory is ideal for multinational companies or residents abroad who perform activities in Mexico. The most important are as follows:
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Definition of an Investment Program for Mexico, either through permanent residence, incorporation of a domestic subsidiary or real estate trusts for those who intend to explore such a dynamic industry in Mexico.
Corporate structure diagnostics and if applicable, restructuring planning for obtaining a higher efficiency.
Opinion on applicability and scope of treaties to prevent double taxation and any tax evasion for which Mexico has executed treaties with a great number of countries and has made remarks to the OCDE’s model.
Review and writing of any kind of agreement necessary for performing any activity between related parties thus providing legal certainty as to payments abroad, such as dividends, interest, royalties, wages, cash pooling, etc.
Proper Business Benefit treatment application.
Preparation and establishment of the domestic Profits and Income Tax provision for companies that require reporting based on US GAAP and pursuant to that provided for in FAS109, either annually or quarterly.
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Advisory on preparation of the FIN48 report or Income Tax Uncertainty recording for companies that report based on US GAAP.
Integral advisory on international taxes and transfer prices in collaboration with Quorum Consulting Group, S.C., an associated firm specialized in this field.
Outbound Transactions Advisory.
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This conception considers tax treatment for abroad transactions by Mexican taxpayers, as follows:
International passive transactions, such as collection of dividends, royalties, income, interest, etc.
International active transactions, such as incorporation and operation of foreign subsidiaries or branches.
In both cases, determination of eligibility for possible tax credits.
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