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United States ↔ Mexico · Worked example

A US manufacturer sets up a nearshore plant in Mexico

A US manufacturer sets up a Mexican subsidiary to run a production plant that imports components, manufactures or assembles goods and ships most of the output back to the United States. It must meet US tax, reporting, trade and export control rules on the outbound side, and Mexico's foreign investment, tax, customs, employment and immigration rules for the plant.

Source-checked research100% of statements checked against a source31 checked against an official source9 checked against a secondary sourceChecked 2026-10-19Not yet professionally reviewed

This journey assumes

  • The US parent is a US corporation with no Mexican operations today and will own the Mexican company directly or through a US holding company.
  • Most of the plant's output will be exported to the United States and sold by the US group; a smaller share may be sold to customers in Mexico.
  • The plant's activity (general manufacturing or assembly) is not reserved or restricted under Mexico's Foreign Investment Law; this must be checked for the specific sector.
  • A small number of US managers and engineers will move to Mexico; most staff will be hired locally.
  • Rules are stated as at 19 October 2026. US tariff measures, Mexico's tariff schedule and USMCA arrangements changed repeatedly in 2025 and 2026 and must be re-checked on the date of entry.

If any assumption is wrong for your business, the conclusions change. Ask WONE Global to re-run the analysis with your facts.

Both sides of the border, issue by issue

Each row is one part of the work. The left and right columns show what each country's rules require, so you can see where one side's decision constrains the other.

Part of the workUnited StatesMexico

Setting up and reporting the Mexican investment

The United States has no general approval process for investing in Mexico, but the US parent takes on annual information reporting for a foreign subsidiary and may be asked to file BEA surveys. In Mexico, a company with foreign shareholders must register with the National Registry of Foreign Investments, and the plant's sector must be checked against the Foreign Investment Law.

United States
  • The US parent files Form 5471 and its schedules each year for the Mexican company, meeting the reporting requirements of sections 6038 and 6046; current instructions are dated December 2025.1
  • BEA's quarterly BE-577 survey is mandatory for US persons owning 10% or more of a foreign business when BEA contacts them, for affiliates above USD 500 million in assets, sales or net income; a new plant is unlikely to meet this at first, but the group may already be a reporter.2
  • US persons, including the parent and any US officers who sign on the Mexican company's bank accounts, must check whether they have to file an FBAR where foreign accounts exceed USD 10,000 in aggregate during the year.3
More in the United States guide →
Mexico
  • Foreign investment is governed by the federal Foreign Investment Law, last amended in May 2024. Check the plant's activity against its reserved and restricted activities before committing.4
  • The Mexican company must apply to register with the RNIE within 40 working days of the US capital entering its share capital. The official guidance found predates the latest amendments, so the current procedure should be confirmed.5
More in the Mexico guide →

Choosing the operating model and the Mexican vehicle

Nearshore plants are usually run by a Mexican subsidiary operating under an IMMEX programme. The main choice is whether the subsidiary owns its inventory and sells to the US group, or works as a maquila on materials and equipment owned by the US parent, which changes the Mexican permanent establishment and transfer pricing analysis. The legal form also decides how the US treats the subsidiary for tax.

United States
  • A Mexican Sociedad Anonima, including the variable capital S.A. de C.V., is a per se corporation for US tax purposes and cannot change its classification.67
  • Forms not on the per se list, such as the S. de R.L. de C.V., can be eligible entities able to elect their US classification on Form 8832, for example as a disregarded entity; the choice changes how the plant's income is reported by the US parent.67
  • Under a maquila model the US parent owns the machinery and inventory in Mexico, so intercompany contracts, asset records and export control classifications of the equipment sent south must reflect that ownership.89
More in the United States guide →
Mexico
  • An IMMEX programme suspends import duty on raw materials temporarily imported for export production, and VAT on temporary imports of raw materials and fixed assets is avoided with a VAT certification or a bond.10
  • Under the maquila rules a US principal that owns the equipment and inventory is treated as having no permanent establishment in Mexico only if it can rely on the US-Mexico treaty, complies with it, and the maquila meets the transfer pricing provisions.811
  • Mexico generally prohibits subcontracting of personnel. Any model where a third party (for example a shelter provider) employs the plant's production workforce must be checked against the specialised services exception.12
More in the Mexico guide →

Tax on both sides

The Mexican company pays 30% corporate income tax, shares 10% of adjusted taxable income with employees and charges 16% VAT. Dividends to the US parent carry Mexican withholding of 10% under domestic law, reduced to 5% or 0% under the US-Mexico treaty. In the United States, from 2026 the parent includes net CFC tested income each year and can generally deduct the foreign-source portion of dividends it receives.

United States
  • The US and Mexico have an income tax treaty. IRS Table 1 shows dividend rates of 10% generally, 5% at the direct dividend rate and 0% for dividends from an 80%-owned subsidiary meeting ownership-period and limitation on benefits conditions.1113
  • Treaty rates are 4.9%, 10% or 15% on interest depending on the lender and type of debt, and 10% on royalties, which matters for intercompany loans and for licensing US technology to the plant.1415
  • From tax years beginning after 31 December 2025 the US parent includes its net CFC tested income (formerly GILTI) from the Mexican company each year, with a 40% deduction under section 250.1617
  • A 10% US corporate shareholder can generally deduct the foreign-source portion of dividends from the Mexican company under section 245A, so the Mexican withholding on those dividends should be modelled with US advisers; US-parented groups above the threshold also file country-by-country reports on Form 8975.1819
More in the United States guide →
Mexico
  • Mexican corporate income tax is 30% at federal level and applies to the subsidiary's profits.20
  • Dividends paid abroad out of profits generated from 2014 carry 10% Mexican withholding, reduced under the US treaty to 5% for a holder of at least 10% of voting shares and potentially 0% for substantial holdings.2113
  • Employers pay 10% of adjusted taxable income to employees as profit sharing (PTU), with none due in the first year of operations, and VAT is 16%.2223
  • Transactions with the US group must be at arm's length with a contemporaneous transfer pricing report, and a local file is due by 15 May above a threshold. The January 2025 Plan Mexico decree allows immediate deduction of new fixed assets at 35% to 91%, subject to conditions not confirmed here.2425
More in the Mexico guide →

Moving inputs and finished goods across the border

Inputs enter Mexico under the IMMEX programme and finished goods enter the United States, where duty depends on USMCA origin and on Section 232 and other tariff measures that changed repeatedly in 2025 and 2026. US equipment and technology sent to the plant must be cleared under US export controls.

United States
  • Mexico is one of the 20 US free trade agreement partners. USMCA has been in force since 1 July 2020, and a preference claim needs a certification of origin with the nine minimum data elements and goods that meet the USMCA rules of origin.2627
  • The additional IEEPA-based duties ended in February 2026, but Section 232 duties were expressly unaffected and further Section 232 investigations cover products such as copper, semiconductors and trucks; check the measures in force on the date of entry.2829
  • Machinery, software and technical data sent to the plant are subject to the Export Administration Regulations; most items will be EAR99, but controlled items need classification and may need a licence.9
More in the United States guide →
Mexico
  • Under IMMEX, raw materials temporarily imported for export production enter without import duty as long as they are exported.10
  • Mexico's tariff law (LIGIE) was amended as recently as 13 October 2026 and the Customs Law in December 2025. The content of these reforms was not confirmed here, so duty on inputs from outside North America must be checked by tariff line.3031
More in the Mexico guide →

Staff, visas and social security

The Mexican company must register with IMSS and enrol its workers. US managers moving to Mexico need work authorisation from the INM, requested by the Mexican employer. There is no US-Mexico social security agreement in force, so seconded staff may face contributions in both countries.

United States
  • Mexico is not on the SSA list of countries with US social security agreements, so there is no treaty rule keeping seconded US staff in the US system only.32
  • US social security tax is 6.2% each for employer and employee on wages up to USD 184,500 in 2026; whether it continues for staff working in Mexico depends on how the secondment is structured and should be confirmed.3332
More in the United States guide →
Mexico
  • Everyone providing paid, subordinate services is covered by mandatory social security; the employer must register with IMSS and report hires, departures and salary changes within five working days.3435
  • To hire a US national the Mexican employer applies to the INM, which decides within 20 working days; the worker then takes the authorisation letter to a Mexican consulate. The consular page describing this dates from 2016, so current requirements should be confirmed.36
  • Profit sharing (PTU) at 10% of adjusted taxable income is a material employment cost from the second year of operations.22
More in the Mexico guide →

Anti-corruption, sanctions, data and disputes

The US parent stays exposed to the FCPA and US sanctions for what happens at the plant. The Mexican company is subject to Mexico's new private-sector data protection law. Both countries apply the New York Convention, which supports arbitration clauses in supply and customer contracts.

United States
  • The FCPA remains law and the US parent should treat payments by the plant and its agents in Mexico as within its compliance programme; Executive Order 14209 of February 2025 paused new enforcement pending a policy review but did not repeal it.37
  • OFAC sanctions apply to the US parent and its staff; customs brokers, suppliers and logistics partners in Mexico should be screened.38
Mexico
  • A new Federal Law on the Protection of Personal Data Held by Private Parties was issued on 20 March 2025; the basis for sharing employee data with the US parent under it was not confirmed here.39
  • Mexico has applied the New York Convention since 1971 without reciprocity or commercial reservations, which supports arbitration clauses with Mexican suppliers and customers.40

Structures to consider

01

Mexican subsidiary under IMMEX that owns its inventory (contract or full-risk manufacturer)20222410161

Fits when The plant will buy its own inputs and sell finished goods to the US group, the group expects a long-term presence, and some output may be sold in Mexico.

Watch for Mexican corporate tax at 30%, PTU at 10% and transfer pricing documentation apply to the plant's profit; IMMEX conditions must be maintained; the US parent includes net CFC tested income and files Form 5471.

02

IMMEX maquila working on materials and equipment owned by the US parent811109

Fits when The US parent wants to keep ownership of machinery, inventory and technology, and nearly all output returns to the United States.

Watch for Protection from a Mexican permanent establishment depends on treaty eligibility, compliance with the treaty and the maquila transfer pricing rules; US-owned equipment in Mexico needs export control classification; sales into the Mexican market fit poorly.

03

Start under a shelter provider, then move to the group's own subsidiary1210

Fits when The group wants to start production quickly and test the location before hiring a workforce and obtaining its own IMMEX programme.

Watch for Mexico's general ban on subcontracting of personnel must be checked against the arrangement; shelter structures and the later transfer of staff and assets were not source-checked.

These are the structures businesses commonly weigh, not a recommendation. The right one depends on the facts listed under "What we need from you".

What has to happen first

  1. United StatesUS board approves the project, budget and preferred operating model (owned inventory, maquila or shelter start).
  2. Both sidesMap the products, tariff classifications and origin of inputs; model USMCA eligibility, Section 232 exposure and Mexican duty on non-North American inputs.After step 1
  3. Both sidesCheck the activity against the Foreign Investment Law and choose the Mexican form (S.A. de C.V. or S. de R.L. de C.V.) together with its US tax classification.After step 1
  4. MexicoIncorporate the Mexican company, obtain its tax registration and open bank accounts.After step 3
  5. MexicoContribute capital and apply for RNIE registration within 40 working days.After step 4
  6. United StatesFile any Form 8832 election and set up Form 5471, FBAR and BEA reporting in the US group.After step 4
  7. MexicoApply for the IMMEX programme and the VAT certification for temporary imports.After step 4
  8. United StatesClassify equipment, software and technical data to be sent to the plant under the Export Administration Regulations and obtain any licences.After step 2
  9. Both sidesSign intercompany manufacturing, supply, licence and services agreements and set a transfer pricing policy that works in both countries (including the maquila safe harbour if relevant).After step 2, 3
  10. Both sidesRegister the employer with IMSS, hire local staff and obtain INM work authorisation for US staff moving to Mexico; settle their US and Mexican social security position.After step 4
  11. Both sidesStart production: temporary imports under IMMEX, exports to the US with USMCA certifications of origin where claimed, and screening of suppliers and brokers.After step 5, 7, 8, 9, 10
  12. Both sidesOngoing compliance: Mexican returns, PTU and transfer pricing local file; US Form 5471, net CFC tested income and any BEA surveys.After step 11

What we need from you before anyone can advise

  • Products, tariff classifications and where inputs come from (North America, Asia or elsewhere).
  • Share of output going to the US group versus Mexican or third-country customers.
  • Whether the US parent will own machinery, inventory and technology used in Mexico.
  • Value and timing of capital expenditure, and whether the Plan Mexico deduction conditions can be met.
  • Headcount, how many US staff will move and for how long, and who will employ them.
  • Group consolidated revenue and existing BEA reporter status.
  • Whether any equipment, software or technology is controlled under the Export Administration Regulations.
  • Planned location of the plant, including any state incentives and state payroll tax.

What this guide does not yet confirm

These points need checking with a qualified local professional before you rely on them.

  • The Mexican income tax law (LISR) on the Chamber of Deputies site could not be downloaded; the 30% rate, dividend withholding, maquila and transfer pricing points rely on PwC Worldwide Tax Summaries.
  • The official US-Mexico treaty text and protocols could not yet be checked; treaty rates rely on IRS Table 1 (revision May 2023).
  • Mexico's general exchange control position, bank account opening and KYC expectations were not source-checked.
  • The content of the 13 October 2026 LIGIE reform and the December 2025 Customs Law reform, including any tariff increases on goods from countries without a trade agreement with Mexico, was not confirmed.
  • IMMEX programme requirements, temporary import time limits, the VAT certification process and shelter (albergue) arrangements were not confirmed on Ministry of Economy or SAT pages.
  • The status and outcome of the 2026 USMCA joint review, and USMCA rules of origin for specific products, were not confirmed.
  • The April 2021 subcontracting reform, REPSE registration rules and their tax consequences could not yet be checked on official pages.
  • The current INM work visa procedure and the residence card exchange after entry were not confirmed; the consular page found dates from 2016.
  • Mexico's data transfer rules and regulator under the 2025 LFPDPPP, and Mexican anti-corruption law, were not source-checked.
  • Whether US social security continues for US staff working in Mexico depends on the secondment structure and was not confirmed.

Brief for your advisers

Questions to put to your advisers in each country. Copy them, or download them as a text file to send with your requirement.

  1. Mexican tax adviser: does the maquila model give our US parent protection from a Mexican permanent establishment, and which transfer pricing option (safe harbour or other) is available to us?
  2. Mexican corporate adviser: is our activity open to 100% foreign ownership, and should we use an S.A. de C.V. or an S. de R.L. de C.V. given our US tax classification plans?
  3. US tax adviser: how will net CFC tested income, section 245A and foreign tax credits work for the plant, and should we elect a different classification on Form 8832?
  4. Both tax advisers: what treaty rate applies to dividends, interest and royalties from the plant, and do we meet the limitation on benefits conditions for the 0% dividend rate?
  5. Customs adviser: what does IMMEX require of us, and what is the current Mexican duty on our non-North American inputs after the 2025 and 2026 tariff reforms?
  6. US trade adviser: which of our products qualify for USMCA, and which Section 232 or other tariff measures apply on entry to the US?
  7. Mexican employment adviser: can we use a shelter provider without breaching the subcontracting ban, and what are our IMSS, PTU and state payroll tax obligations?
  8. Immigration and payroll advisers: what is the current INM process for our US managers, and how do we avoid double social security contributions without a US-Mexico agreement?
  9. Export control adviser: do any of the machines, software or technical data we send to Mexico need a licence or a deemed export review?

Who can help, on each side

United States

Mexico

Sources and review status

Each statement is numbered to the source it was checked against. We use official sources where we can, and each statement says whether it was checked against an official or a secondary source. Sources last checked on 19 October 2026. None of it has been professionally reviewed yet: it is research checked against official and secondary sources by WONE Global, not legal or tax advice.

  1. Certain US persons who are officers, directors or shareholders of certain foreign corporations must file Form 5471 and its schedules to meet the reporting requirements of sections 6038 and 6046 of the Internal Revenue Code. Federal. Current instructions are dated December 2025 (page updated 17 September 2026). The filer categories that apply to a US parent corporation are set out in the instructions, which could not yet be checked in full.

    Internal Revenue Service — About Form 5471 · Purpose of form · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

  2. BEA's quarterly survey of US direct investment abroad (BE-577) is mandatory for each US person with a direct or indirect 10% or more voting interest in a foreign business enterprise, for directly owned affiliates whose total assets, annual sales or net income exceeded USD 500 million, with reports due 30 days after each quarter (45 days for the final quarter). Federal. Only US persons contacted individually by BEA must report. Indirectly owned affiliates are reportable where they meet the USD 500 million test and have intercompany balances with the US reporter above USD 10 million. Other BEA outward surveys (BE-10, BE-11) were not checked.

    Bureau of Economic Analysis, Department of Commerce (Federal Register) — Direct Investment Surveys: BE-577, Quarterly Survey of U.S. Direct Investment Abroad - Transactions of U.S. Reporter With Foreign Affiliate (notice of reporting requirements, document 2026-05074) · Summary and supplementary information · In force from 16 March 2026 · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

  3. A US person, including a corporation, partnership or LLC, with a financial interest in or signature authority over foreign financial accounts whose combined value exceeds 10,000 US dollars at any time in the calendar year must file FinCEN Form 114 (FBAR) electronically, due 15 April of the following year with an automatic extension to 15 October. Federal. Applies to a US subsidiary that holds accounts abroad, for example with its foreign parent's bank.

    Internal Revenue Service (IRS) — Report of Foreign Bank and Financial Accounts (FBAR) · Who must file; when and how to file · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

  4. The Foreign Investment Law (Ley de Inversión Extranjera) is the federal statute governing foreign investment; its last amendment listed by the Chamber of Deputies was published in the Official Gazette (DOF) on 27 May 2024. Federal law; content of the law (sector restrictions, registration duties) not confirmed.

    Cámara de Diputados del H. Congreso de la Unión — Leyes Federales de México (Leyes Federales Vigentes) · Entry: Ley de Inversión Extranjera · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

    Only the listing was read; the PDF of the law could not yet be checked.

  5. Mexican companies must apply to register with the National Registry of Foreign Investments (RNIE) within 40 working days of foreign investment entering their share capital. Federal, Foreign Investment Law article 32. Foreign companies habitually carrying on commercial acts in Mexico must register within 40 working days of starting, and trusts within 40 working days of signature.

    Secretaría de Economía — Registro Nacional de Inversiones Extranjeras: solicitud de inscripción (guidance document) · Section on who must register and deadlines (LIE art. 32) · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

    The official guidance lists Foreign Investment Law reforms only up to 25 May 2011; the law was last amended on 27 May 2024, so the deadline should be confirmed against the current text.

  6. US entity classification regulations list the Mexican Sociedad Anonima as a per se corporation, always treated as a corporation for US federal tax purposes. The term includes an entity that uses the variable capital provision of Mexican corporate law (S.A. de C.V.). Federal, 26 CFR 301.7701-2(b)(8)(i). Entity forms not on the list may be eligible entities that can choose their classification.

    Legal Information Institute, Cornell Law School (US Code of Federal Regulations) — 26 CFR 301.7701-2 - Business entities; definitions · Paragraph (b)(8)(i) and (b)(8)(ii)(B) · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

    Regulation text reproduced by Cornell LII; the eCFR original could not yet be checked.

  7. An eligible entity uses Form 8832 to elect how it will be classified for US federal tax purposes: as a corporation, a partnership or an entity disregarded as separate from its owner. Federal. Per se corporations on the regulatory list cannot use this election. The IRS also publishes FAQs on Form 8832 for foreign eligible entities (February 2022), not yet checked.

    Internal Revenue Service — About Form 8832, Entity Classification Election · Purpose of form · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

  8. A non-resident principal that owns the machinery, equipment and inventory used by an IMMEX maquila is considered not to have a permanent establishment in Mexico to the extent it is resident in a country with a tax treaty in force with Mexico, complies with the treaty and any mutual agreements, and the maquila complies with the transfer pricing provisions. Federal income tax. PwC states that only the safe harbour transfer pricing alternative is applicable to maquilas; the statutory options in the income tax law could not yet be checked and should be confirmed.

    PwC Worldwide Tax Summaries — Mexico - Corporate - Income determination · Maquiladoras (IMMEX) · Checked 19 October 2026 · Checked against a secondary source · Not yet professionally reviewed

    Secondary source (last reviewed 6 August 2026). The Ley del Impuesto sobre la Renta on the Chamber of Deputies site could not be downloaded, so the statutory text could not yet be checked.

  9. Items subject to the Export Administration Regulations include all items in the United States, all US-origin items wherever located, certain foreign-made items incorporating controlled US-origin content above de minimis levels and certain foreign-produced direct products, and items subject to the EAR but not listed on the Commerce Control List are designated EAR99. Federal, 15 CFR 734.3(a) and (c), administered by the Bureau of Industry and Security. Whether a licence is needed depends on the item's classification, destination, end user and end use. Defence articles under ITAR are outside this claim.

    Office of the Federal Register (eCFR) — 15 CFR 734.3 Items subject to the EAR · Section 734.3(a) and (c) · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

    The eCFR is an authoritative but unofficial editorial compilation; the official text is the annual CFR edition and Federal Register.

  10. IMMEX maquiladoras pay no import duty on temporarily imported raw materials as long as they are exported, and temporarily imported raw materials and fixed assets are not subject to VAT where the importer holds a VAT certification or posts a bond guaranteeing the VAT until export. Federal customs and VAT benefits of the IMMEX programme, which is granted by the Ministry of Economy. Time limits for temporary imports were not confirmed.

    PwC Worldwide Tax Summaries — Mexico - Corporate - Tax credits and incentives · Maquiladoras (IMMEX) · Checked 19 October 2026 · Checked against a secondary source · Not yet professionally reviewed

    Secondary source (last reviewed 6 August 2026). The Ley del Impuesto sobre la Renta on the Chamber of Deputies site could not be downloaded, so the statutory text could not yet be checked.

  11. The IRS list of the United States income tax treaties includes Mexico. Comprehensive income tax treaties listed by the IRS. The IRS also notes that some US states do not honour tax treaty provisions.

    Internal Revenue Service — United States income tax treaties - A to Z · Alphabetical list of treaty countries · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

  12. Mexican law generally prohibits subcontracting of personnel and permits only specialised services or works that do not form part of the client's corporate purpose, as reaffirmed by the Supreme Court in June 2023. Federal labour law. The Ministry of Labour (STPS) runs the registration procedure for specialised service providers but, per the Court, cannot define what counts as specialised.

    EY Mexico — Law Flash: SCJN - servicios especializados (27 June 2023) · Summary of amparo en revisión 687/2022 · Checked 19 October 2026 · Checked against a secondary source · Not yet professionally reviewed

    Secondary source. The April 2021 reform text, the REPSE registration rules and the tax consequences of non-compliant subcontracting could not yet be checked on official pages.

  13. IRS Table 1 shows US-Mexico treaty rates on dividends of 10% generally and 5% at the direct dividend rate, and an exemption for dividends from an 80%-owned corporate subsidiary where ownership-period and limitation on benefits conditions are met. Treaty Article 10 as amended by protocol. The direct dividend rate generally applies to dividends from a subsidiary to a parent holding at least 10%.

    Internal Revenue Service — Tax Treaty Table 1: Tax Rates on Income Other Than Personal Service Income Under Chapter 3, Internal Revenue Code, and Income Tax Treaties (Rev. May 2023) · Mexico row, income codes 6 and 7, footnotes b, dd, mm and oo · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

    Table 1 shows rates on US-source income received by Mexican residents; the treaty articles are reciprocal and the Mexican-side rates are confirmed separately (see the PwC Mexico withholding claim). Table revision May 2023; no later protocol was identified on the IRS treaty list.

  14. IRS Table 1 shows US-Mexico treaty rates on interest of 4.9% on loans from banks and insurance companies and on regularly traded securities, 10% on interest paid by banks and on credit sales of machinery and equipment, and 15% otherwise, with exemptions for certain government and pension recipients. Treaty Article 11.

    Internal Revenue Service — Tax Treaty Table 1: Tax Rates on Income Other Than Personal Service Income Under Chapter 3, Internal Revenue Code, and Income Tax Treaties (Rev. May 2023) · Mexico row, income code 1, footnote hh · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

    Table 1 shows rates on US-source income received by Mexican residents; the treaty articles are reciprocal and the Mexican-side rates are confirmed separately (see the PwC Mexico withholding claim). Table revision May 2023; no later protocol was identified on the IRS treaty list.

  15. IRS Table 1 shows a US-Mexico treaty rate of 10% on royalties, including industrial royalties, know-how and copyrights. Treaty Article 12. Unless the treaty or a competent authority arrangement says otherwise, the copyright rate applies to software royalties.

    Internal Revenue Service — Tax Treaty Table 1: Tax Rates on Income Other Than Personal Service Income Under Chapter 3, Internal Revenue Code, and Income Tax Treaties (Rev. May 2023) · Mexico row, income codes 10 to 12, footnote tt · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

    Table 1 shows rates on US-source income received by Mexican residents; the treaty articles are reciprocal and the Mexican-side rates are confirmed separately (see the PwC Mexico withholding claim). Table revision May 2023; no later protocol was identified on the IRS treaty list.

  16. For taxable years beginning after 31 December 2025, each United States shareholder of a controlled foreign corporation must include its net CFC tested income in gross income; Public Law 119-21 renamed this inclusion from global intangible low-taxed income (GILTI). Federal, 26 USC 951A as amended by Pub. L. 119-21, section 70323. Applies to US shareholders (generally 10% owners) of controlled foreign corporations.

    Legal Information Institute, Cornell Law School (US Code) — 26 U.S. Code 951A - Net CFC tested income included in gross income of the United States shareholders · Subsection (a) and amendment notes · In force from 1 January 2026 · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

  17. For taxable years beginning after 31 December 2025, a domestic corporation may deduct 40% of its net CFC tested income amount (with the related section 78 amount), reduced from 50%, and 33.34% of its foreign-derived deduction eligible income, reduced from 37.5%. Federal, 26 USC 250(a)(1) as amended by Pub. L. 119-21, section 70321.

    Legal Information Institute, Cornell Law School (US Code) — 26 U.S. Code 250 - Foreign-derived deduction eligible income and net CFC tested income · Subsection (a)(1) and effective-date note · In force from 1 January 2026 · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

  18. A domestic corporation that is a United States shareholder of a specified 10-percent owned foreign corporation may deduct the foreign-source portion of dividends received from it. Federal, 26 USC 245A(a). Does not apply to hybrid dividends (245A(e)), where the foreign company obtained a deduction or other tax benefit for the payment. Holding period and foreign tax credit interactions could not yet be checked.

    Legal Information Institute, Cornell Law School (US Code) — 26 U.S. Code 245A - Deduction for foreign source-portion of dividends received by domestic corporations from specified 10-percent owned foreign corporations · Subsections (a) and (e) · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

  19. US-parented multinational groups report country-by-country information to the IRS on Form 8975 and its Schedule A. US federal; the revenue threshold is not stated on this IRS page.

    Internal Revenue Service (IRS) — Country-by-country reporting · Page text and form links · Checked 18 October 2026 · Checked against an official source · Not yet professionally reviewed

  20. The federal corporate income tax rate in Mexico is 30%. Federal. Applies to Mexican companies and to income attributed to permanent establishments of foreign residents.

    PwC Worldwide Tax Summaries — Mexico - Corporate - Taxes on corporate income · Corporate income tax rate · Checked 19 October 2026 · Checked against a secondary source · Not yet professionally reviewed

    Secondary source (last reviewed 6 August 2026). The Ley del Impuesto sobre la Renta on the Chamber of Deputies site could not be downloaded, so the statutory text could not yet be checked.

  21. Mexico withholds 10% on dividends paid to non-residents, and under the US-Mexico treaty the rate is 10% for portfolio holdings and 5% or 0% for substantial holdings, the 5% rate applying where the recipient owns at least 10% of the voting shares. Federal. No withholding applies to distributions of profits taxed at corporate level generated before 2014. Distributions of earnings never subject to corporate tax trigger corporate tax on a grossed-up amount (factor 1.4286). Domestic rates on interest (up to 35%) and royalties (25% or 35%) are reduced by the treaty.

    PwC Worldwide Tax Summaries — Mexico - Corporate - Withholding taxes · Withholding tax table and notes · Checked 19 October 2026 · Checked against a secondary source · Not yet professionally reviewed

    Secondary source (last reviewed 6 August 2026). The Ley del Impuesto sobre la Renta on the Chamber of Deputies site could not be downloaded, so the statutory text could not yet be checked.

  22. Mexican employers distribute 10% of adjusted taxable income to employees as profit sharing (PTU); general directors and managers are excluded and no profit sharing is paid in the first year of operations. Federal. Also a payroll-related cost: most states levy a payroll tax on the employer (3% in Mexico City).

    PwC Worldwide Tax Summaries — Mexico - Corporate - Other taxes · Employee profit sharing; payroll taxes · Checked 19 October 2026 · Checked against a secondary source · Not yet professionally reviewed

    Secondary source (last reviewed 6 August 2026). The Ley del Impuesto sobre la Renta on the Chamber of Deputies site could not be downloaded, so the statutory text could not yet be checked.

  23. Mexican VAT is charged at a general rate of 16% on sales of goods and services. Federal. Reduced or border-region rates were not confirmed.

    PwC Worldwide Tax Summaries — Mexico - Corporate - Other taxes · Value-added tax · Checked 19 October 2026 · Checked against a secondary source · Not yet professionally reviewed

    Secondary source (last reviewed 6 August 2026). The Ley del Impuesto sobre la Renta on the Chamber of Deputies site could not be downloaded, so the statutory text could not yet be checked.

  24. Mexican related-party transactions must be carried out at arm's length and supported by a contemporaneous transfer pricing report; for taxpayers above a threshold the local file is due on 15 May and the master file on 31 December of the following year. Federal. The threshold is not quantified in the source. Failure to file can lead to fines, exclusion from public contracts or cancellation of customs permits.

    PwC Worldwide Tax Summaries — Mexico - Corporate - Group taxation · Transfer pricing · Checked 19 October 2026 · Checked against a secondary source · Not yet professionally reviewed

    Secondary source (last reviewed 6 August 2026). The Ley del Impuesto sobre la Renta on the Chamber of Deputies site could not be downloaded, so the statutory text could not yet be checked.

  25. A presidential decree published on 21 January 2025 under the Plan Mexico strategy introduced immediate deduction of investments in new fixed assets, at rates from 35% to 91% depending on the asset type. Federal incentive. Eligibility conditions, application procedure and expiry date were not confirmed.

    PwC Worldwide Tax Summaries — Mexico - Corporate - Tax credits and incentives · Plan Mexico · In force from 22 January 2025 · Checked 19 October 2026 · Checked against a secondary source · Not yet professionally reviewed

    Secondary source (last reviewed 6 August 2026). The Ley del Impuesto sobre la Renta on the Chamber of Deputies site could not be downloaded, so the statutory text could not yet be checked. The effective date is assumed to follow publication and must be confirmed in the decree.

  26. The United States has comprehensive free trade agreements in force with 20 countries: Australia, Bahrain, Canada, Chile, Colombia, Costa Rica, the Dominican Republic, El Salvador, Guatemala, Honduras, Israel, Jordan, Korea, Mexico, Morocco, Nicaragua, Oman, Panama, Peru and Singapore. Federal. Japan is covered by separate limited agreements (including a critical minerals agreement) that USTR does not count as free trade agreements.

    Office of the United States Trade Representative (USTR) — Free Trade Agreements · Introductory paragraph and list · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

    CBP's free trade agreements page lists the same 14 agreements.

  27. The US-Mexico-Canada Agreement (USMCA) entered into force on 1 July 2020, and a claim for USMCA preferential treatment requires a certification of origin, in any format, containing the nine minimum data elements in USMCA Annex 5-A. Federal. Goods must meet the USMCA rules of origin. The CBP page read was last modified on 25 April 2024 and does not address 2026 developments such as the USMCA joint review.

    US Customs and Border Protection (CBP) — United States-Mexico-Canada Agreement (USMCA) · Overview and certification of origin · In force from 1 July 2020 · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

  28. Executive Order 14389 of 20 February 2026 ended the additional ad valorem duties imposed under IEEPA-based orders and stated that it does not affect other duties, including duties imposed under Section 232. Federal. The order says the IEEPA duties are no longer in effect and are to stop being collected as soon as practicable; the related national emergencies remain in effect.

    Executive Office of the President (Federal Register document 2026-03832) — Ending Certain Tariff Actions · Sections 1 and 2 · In force from 20 February 2026 · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

    Read on the FederalRegister.gov web edition, which describes itself as unofficial; the official text is the Federal Register PDF on govinfo.gov.

  29. A Section 232 investigation by the Department of Commerce determines the effect of imports on national security, with the Secretary's report due within 270 days of initiation, after which the President may adjust imports of the article and its derivatives. Federal. Investigations initiated in 2025 and 2026 cover, among others, copper, timber and lumber, semiconductors, pharmaceuticals, trucks, critical minerals, commercial aircraft, polysilicon, drones, wind turbines, robotics and industrial machinery, medical products and anthracite coal (initiated 29 June 2026).

    Bureau of Industry and Security (BIS), US Department of Commerce — Section 232 Investigations · Programme description and list of investigations · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

    The page lists investigations but not the duty rates or current scope of each resulting proclamation; actions continued in 2026, for example Proclamation 11045 of 20 July 2026 on aluminium (Federal Register document 2026-14990).

  30. The General Import and Export Tax Law (LIGIE), which contains Mexico's tariff schedule, was most recently amended by a reform published in the DOF on 13 October 2026. Federal tariff law; the content of the latest reform was not confirmed.

    Cámara de Diputados del H. Congreso de la Unión — Leyes Federales de México (Leyes Federales Vigentes) · Entry: Ley de los Impuestos Generales de Importación y de Exportación · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

    Only the listing was read. Tariff rates should be checked against the current LIGIE.

  31. The Customs Law (Ley Aduanera) was last amended by a reform published in the DOF on 27 December 2025, and the Foreign Trade Law (Ley de Comercio Exterior) on 1 May 2026. Federal laws; content of the reforms not confirmed.

    Cámara de Diputados del H. Congreso de la Unión — Leyes Federales de México (Leyes Federales Vigentes) · Entries: Ley Aduanera; Ley de Comercio Exterior · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

    Only the listing was read.

  32. The Social Security Administration's list of countries with which the United States has social security (totalization) agreements does not include Mexico. Without an agreement in force there is no treaty rule to prevent the same earnings being subject to both US and Mexican social security contributions.

    Social Security Administration — U.S. International Social Security Agreements · Table: Countries with Social Security Agreements · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

    The page carries a certification date of 25 November 2019 but lists agreements entering into force as late as 1 September 2026, so it is maintained.

  33. For 2026, social security tax is 6.2% each for employer and employee on wages up to a wage base limit of $184,500. Federal (FICA). Wages above the wage base are not subject to social security tax.

    Internal Revenue Service (IRS) — Publication 15 (2026), (Circular E), Employer's Tax Guide · Social security and Medicare taxes · In force from 1 January 2026 · Checked 18 October 2026 · Checked against an official source · Not yet professionally reviewed

  34. Persons who provide paid, personal and subordinate services to another, whatever the act that gives rise to the relationship, are subject to the mandatory social security regime. Ley del Seguro Social, art. 12, fr. I; domestic workers are also covered (fr. IV).

    Cámara de Diputados del H. Congreso de la Unión — Ley del Seguro Social (texto vigente, última reforma DOF 15-01-2026) · Art. 12 · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

  35. Employers must register with the Mexican Social Security Institute (IMSS), enrol their workers and report hires, departures and salary changes within no more than five working days. Ley del Seguro Social, art. 15.

    Cámara de Diputados del H. Congreso de la Unión — Ley del Seguro Social (texto vigente, última reforma DOF 15-01-2026) · Art. 15 · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

  36. To hire a foreign national, the employer in Mexico files the request with the National Migration Institute (INM), which has 20 working days to decide; if approved the employer receives an authorisation letter and the worker then books an appointment at a Mexican consulate. Federal immigration procedure for work-based visas.

    Consulado General de México en Barcelona (Secretaría de Relaciones Exteriores) — Requisitos para Permisos de Trabajo · Procedure description · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

    Official consular page last updated 27 May 2016; current INM requirements, fees and the residence card exchange after entry were not confirmed.

  37. Executive Order 14209, signed on 10 February 2025, directed the Attorney General to review FCPA enforcement policy for 180 days, not to start new FCPA investigations or enforcement actions without an individual exception, and to issue updated guidelines; it did not repeal the Foreign Corrupt Practices Act. Federal. The FCPA (15 USC 78dd-1 and following) remains law, and its statute of limitations is unaffected by the order.

    Office of the Federal Register (GovInfo) — Executive Order 14209: Pausing Foreign Corrupt Practices Act Enforcement To Further American Economic and National Security (90 FR, No. 30, 14 February 2025) · Sections 2 and 3 · In force from 10 February 2025 · Checked 18 October 2026 · Checked against an official source · Not yet professionally reviewed

    The point about the statute of limitations is our reading; the order does not mention it.

  38. The Office of Foreign Assets Control (OFAC), part of the US Treasury, administers and enforces US economic and trade sanctions, using asset blocking and trade restrictions against targeted countries, regimes and persons. Federal. Programmes include Russia-related, Iran, North Korea, Cuba, Venezuela-related, counter-narcotics and cyber-related sanctions.

    US Department of the Treasury, Office of Foreign Assets Control — Office of Foreign Assets Control (home page) · About OFAC · Checked 18 October 2026 · Checked against an official source · Not yet professionally reviewed

  39. A decree published in the DOF on 20 March 2025 issued a new Federal Law on the Protection of Personal Data Held by Private Parties (LFPDPPP), together with a new general transparency law and a new general law on personal data held by public bodies. Private-sector data protection; the competent authority, transfer rules and sanctions under the new law could not be confirmed.

    Diario Oficial de la Federación (via Cámara de Diputados) — DOF 20 de marzo de 2025 (Edición Vespertina): Decreto por el que se expiden la Ley General de Transparencia y Acceso a la Información Pública, la Ley General de Protección de Datos Personales en Posesión de Sujetos Obligados y la Ley Federal de Protección de Datos Personales en Posesión de los Particulares · Decree heading · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

    The retrievable portion of the document ended before the text of the LFPDPPP, so only the decree's existence and scope were confirmed. Corrected after independent source check (round 3, 19 October 2026).

  40. Mexico acceded to the New York Convention on 14 April 1971, with entry into force on 13 July 1971, and made no reciprocity or commercial reservation.

    UNCITRAL — Status: Convention on the Recognition and Enforcement of Foreign Arbitral Awards (New York, 1958) · Row: Mexico · In force from 13 July 1971 · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

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