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C. HOLDING COMPANIES

I. NATIONAL HOLDING COMPANY CONTROLLING ONE OR MORE FOREIGN SUBSIDIARY COMPANIES

103. The Mexican holding company would be taxable on dividends, interest, or other income received from the foreign subsidiaries.

II. LOCAL SUBSIDIARY COMPANY CONTROLLED BY A FOREIGN HOLDING COMPANY

104. Dividends paid by a local subsidiary to a foreign holding company are not subject to any special tax, but interest paid by the local company in respect of bonds issued to the foreign holding company, or loans obtained from the foreign holding company, is subject to withholding of tax by the debtor.

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