In accordance with various fiscal changes from 2014 on, several additional obligations were established for Mexican companies that wish to apply the agreements in order to avoid double taxation; agreeing thereby to a reduced tax rate for applicable transactions with foreign residents. This is designed to prove the residency of foreign companies with which Mexican taxpayers carry out transactions, as well as to limit some deductions; the same which are mentioned below: Tax benefits of the agreements Starting in 2014, the Law on Income Tax includes Article 4, which establishes that Mexican companies that are applying the benefits of the agreed upon fiscal agreements must have the following documentation: For the purposes of showing tax residency, the same can be proven through the issuance of a certificate of residency emitted by the fiscal authorities in the country of residence of the foreigner, as well as the last annual tax return filed in the country where he/she resides (this is a continuation from previous years). • It is worth noting that it is not necessary to authenticate the said certificates in Mexico, and in case the Mexican authorities require it as such, an official translation of the same must be submitted. • Concerning transactions with associated parties, the Mexican authorities will ask the foreign resident to demonstrate that there is double taxation. • According to the previous point, the foreigner will be asked to declare under oath, and signed by his/her legal representative, that he/she specifically indicates that income that is subject to taxation in Mexico, and with respect to which the benefits of the agreement are expected to be applied in order to avoid double taxation, are also taxed in his/her country of residence, indicating the applicable legal provisions, and providing the necessary documentation to that end. Through a facility published in the Ruling on Periodic Amendments, they are considering not asking a foreign resident through his/her legal representative to agree to an imposing of double taxation when:  He/she is a resident of a country with internal revenue for Income Tax.  When he/she is not subject to tax in his/her country, based on an exemption that is foreseen in the agreements entered into by Mexico.  When the sale of shares is carried out under corporate restructuring in accordance with the agreement that the country has with Mexico, and wherever he/she is a resident of.  Whenever it is through dividends, the foreign resident that is the beneficial owner may not be subject to a tax according to the legislation where he/she is a resident. Should you have any further questions or concerns, please don’t hesitate to contact me.