Taxes
Mexico — Tax: Double Tax Treaties
Mexico maintains an extensive double taxation treaty (DTA) network of 59+ agreements, including a comprehensive treaty with the United States (in force since 1994) despite the US not having signed the OECD's Multilateral Instrument (MLI). Mexico is itself a signatory to the MLI, which entered into force for Mexico on 1 July 2023 — MLI provisions generally took effect for withholding taxes from 1 January 2024 and for other taxes from fiscal years beginning on or after that date. Most Mexican DTAs are listed as Covered Tax Agreements (CTAs) under the MLI, implementing BEPS-related treaty measures, though notable exceptions exist: the US-Mexico treaty (US did not sign the MLI), the Germany treaty (updated via a bilateral Protocol instead), and the Indonesia treaty (not listed as a CTA despite Indonesia being an MLI signatory).
Key facts
- 59+ double tax treaties in force, including a comprehensive US-Mexico treaty since 1994.
- Mexico's MLI entered into force 1 July 2023; provisions effective for withholding taxes from 1 Jan 2024, other taxes from FY beginning on/after that date.
- Most Mexican DTAs are MLI Covered Tax Agreements, except the US treaty (US not an MLI signatory), Germany (updated via bilateral Protocol), and Indonesia (not listed as a CTA).
Timelines
- Mexico's MLI entry into force: 1 July 2023
- MLI effective date for withholding taxes: 1 January 2024
Common mistakes
- Assuming MLI/BEPS treaty updates automatically apply to the US-Mexico treaty — the US never signed the MLI, so that treaty follows its original bilateral terms.