B. NATIONAL ENTERPRISES WITH BRANCHES OR SUBSIDIARIES ABROAD
I. GENERAL METHODS OF ALLOCATION
101. An enterprise belonging to a Mexican company or to Mexican citizens, singly or in partnership, is taxable on the whole of its profits derived from operating abroad as well as in Mexico. Consequently, there is no question of allocation or apportionment. The declaration of the taxpayer, as supported by its accounts, is taken as the basis of assessment, subject of course to verification, and, if necessary, to the making of an empirical assessment.
II. ALLOCATION OF PROFIT TO REAL CENTRE OF MANAGEMENT WITHIN THE COUNTRY
102. A Mexican company and Mexican citizens are taxable on the whole of their business profit, and consequently there is no question of any special allocation of profit to the real centre of management of their enterprise in Mexico. If a company organised abroad has its real centre of management in Mexico, it would be taxable on income from transactions realised by such an establishment, but otherwise no income would be allocated to the establishment by reason of management alone.