KPMG report: Mexico’s general anti-abuse rule does not apply retroactively (Federal Tax Court decision)
A KPMG report that discusses the decision and implications for taxpayers.
A KPMG report that discusses the decision and implications for taxpayers.
The Ninth Regional Metropolitan Chamber of the Federal Tax Court recently issued a decision regarding application of Mexico’s general anti-abuse rule (GAAR), which was introduced in 2020 under Article 5-A of the Federal Tax Code.
The main conclusion of the decision is that Article 5-A cannot be applied retroactively. However, a deeper analysis of the decision provides additional insights on how the GAAR applies and its interaction with other anti-abuse tools.
Read a June 2024 report* prepared by KPMG LLP that discusses the decision and its implications for taxpayers.
*Reproduced with permission from Tax Management International Journal, 6/13/2024. Copyright @ 2024 by Bloomberg Industry Group, Inc. (800-372-1033) http://www.bloombergindustry.com
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