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May 7, 2018
2018-0958

Philippines-Mexico Income Tax Treaty enters into force

The Philippines-Mexico Income Tax Treaty (the Treaty) entered into force on April 18, and will become effective on January 1, 2019. Significant provisions in the Treaty include:

- Computation of the time limits in determining the existence of a permanent establishment (PE) in relation to the activities carried on by an associated enterprise within a Contracting State
- Expanded coverage of taxable business profits under Article 7
- Withholding tax rates for dividends, interest and royalties
- Exemption from capital gains on the transfer of property between members of the same group of companies
- Additional taxable capital gains on the alienation of shares
- Provisions against treaty abuse

A Global Tax Alert, attached below, provides additional details.

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