As part of the tax reform enacted on 9 December 2019, Mexico established a new reportable transaction obligation in Articles 197 to 202 of the Federal Fiscal Code (FFC).
Article 197 of the FFC generally requires tax advisors to disclose reportable transactions. Transactions are reportable to the extent there is a tax benefit in Mexico, regardless of the residence of the taxpayer receiving the benefit. The new articles of the FFC further provide that in certain instances the taxpayer is requi…