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1. TAXPAYERS

(a) INDIVIDUALS

6. Mexican citizens are taxable in accordance with the principle of nationality and are therefore liable, whether domiciled in Mexico or abroad, in respect of their total income from all sources, Mexican or foreign.

7. Aliens, regardless of where they reside, are taxed only on income from sources of wealth situated or transactions realised in Mexican territory (Law, Article 1).

(b) PARTNERSHIPS

8. A partnership (sociedad in nombre collectivo) is taxed in the same manner as a corporation, and the partners are not taxed in regard to their distributive shares.

(c) COMPANIES

9. Companies, including corporations (sociedades anonimas), like individuals are taxable on their total income from all sources if they are organised in Mexico, but are taxable only on income from sources of wealth situated, or from transactions realised, in Mexico if they have been organised under the law of a foreign country. This rule applies regardless of where the company may have its real centre of management or where it may be domiciled or resident in accordance with the law of a foreign country.

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