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CMS Expert Guide to Mastering OECD's Pillar Two in Mexico

Key stages in the introduction of global minimum taxation

Table of contents
  1. Has there been a formal indication of the intention to implement Pillar Two/GloBE rules?
  2.  What is the implementation status of Pillar Two/GloBE rules?
  3.  Have your tax authorities published guidelines commenting on Pillar Two/GloBE rules?
  4.  When will the Income Inclusion Rule (IIR) come into force?
  5.  When will the Undertaxed Payments Rule (UTPR) come into force? 
  6.  Is there any intention to implement a Qualifying Domestic Minimum Top-Up Tax (QDMTT)? If so, when?
  7. Further comments
Mexico
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1.Has there been a formal indication of the intention to implement Pillar Two/GloBE rules?

Yes.

2. What is the implementation status of Pillar Two/GloBE rules?

Not yet initiated.

3. Have your tax authorities published guidelines commenting on Pillar Two/GloBE rules?

No.

4. When will the Income Inclusion Rule (IIR) come into force?

There is no specific date yet.

5. When will the Undertaxed Payments Rule (UTPR) come into force? 

There is no specific date yet.

6. Is there any intention to implement a Qualifying Domestic Minimum Top-Up Tax (QDMTT)? If so, when?

There is no specific date yet.

7. Further comments

On October 10, 2022 the Head of the Mexican Finance Ministry stated publicly Mexico’s intention to implement Pillar Two rules, which were expected to be carried out in the course of FY 2023 and come into effect during FY 2024. However no advance have been made until November 2023, and it is not foreseeable that those deadlines will be met.