Emerging Markets Rates and Currencies Handbook

Tax Summary – Mexico Mexico • Restrictionon payments to PTR in line with BEPS action 2 subtracted from taxable income Deductibility of (FX) Losses • Yes • "FX Derivatives”: MTM losses deductible at end of year (if differ from exercise date) • “Other derivatives”: losses deductible on a realized basis • N/A Other Taxes/Duties • N/A • N/A • N/A • N/A • N/A Comments • Strict rules affecting related- party collateralized bank loans • N/A Note: Citigroup Inc. and any of its affiliates do not provide accounting, tax, or legal advice. Please seek advice from a relevant licensed advisor. Source: Relevant legislation, publicly available sources Country Tax Deductibility and Considerations Inter-Co Debt Offshore Derivatives Equities Local Borrowing Bank Loans Offshore