We present the current miscellaneous rule corresponding to the mechanics of presentation of announcements and other information in relation to the sale of shares.

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 On December 20th, 2017, the Chamber of Representatives and the Senate that make up the Congress in the USA approved the "Tax Reform Project", proposed by the Republican Party and strongly promoted by the head of the Executive Power, among others the reform includes the following:

1. Reduction of the Income Tax (ISR) of the companies, from 35 to 21%.
2. Tax deduction of 20% for owners of small businesses.
3. Cancellation of the costs of new equipment by corporations.
4. Eliminate the alternative minimum tax to companies. The current seven individual tax brackets would be maintained, with rates of 10, 12, 22, 24, 32, 35% and a maximum rate of 37% for taxpayers with higher income, which currently stands at 39.6%.

OPTIMIZATION OF THE INCOME TAX BASE

1. Allow 100% deduction of investments in automobiles, via tax depreciation (25% annual) that are used in the activity of the company.
2. Do not limit the deduction on restaurant meals when these meals are business.
3. Do not limit the deduction of social security benefits to 53% and allow them to 100%.

TAX INCENTIVES

1. Allow all taxpayers the immediate deduction in investments, in new goods, mainly in machinery and equipment, without the limitation of $100,000,000 of income.
2. Capital Repatriation Decree, since the decree that was issued in this regard was active until October 19th, 2017.

INCOME TAX RATE

1. Lower the maximum rate for individuals from 35% to 30%, as it was until December 31st, 2013.
2. Allow the 10% withholding tax for dividends paid to individuals residing in Mexico to be creditable and not be considered as a final payment, as it is now in the Income Tax Law.

ADMINISTRATIVE SIMPLIFICATION

1. Simplify the emission of Internet Digital Invoice (CFDI), since its implementation has been very complex today.

COMBAT THE TAX EVASION

1. Exercise the tax acts permitted by the Law allows to all those individual and legal entities, who having the obligation to pay taxes and are not doing so, just like it is provided by the tax laws. From the above, it follows that there are many opportunities in Mexico to maintain existing investments and attract new investors, both residents of Mexico and other countries.

The contracting of derivative financial operations (OFD) has increased significantly in recent years in Mexico, due to the coverage needs of companies that, either because of their structure or exposure to risk, require these instruments to be used with the purpose of limiting losses or maximizing profits.

Among the most common contracts we find forwards, swaps, options and cross currency swaps, which may have as underlying commodities, shares or stock indexes, interest rates or baskets of debt instruments and some currencies.   In the provisions there are rules on tax treatment that must be assigned to these operations at the time of their agreement, during their validity and at their natural or anticipated expiration.

A few weeks before the deadline for the presentation of the annual statement for 2017 and the Informative Statement on Tax Situation (DISIF), it is necessary to carry out an in-depth analysis of the tax effects of these operations on the Income Tax , cash, deferred, Value Added Tax and withholdings that may apply, which allow them to make sure that the assigned treatment has been correct.

The following are some of the most relevant aspects to be considered of the Derivative Financial Transactions:

• Business reason in the celebration of derivative financial transactions (hedging or negotiation and its strict indispensability).
• Formalities in the contracting of Derivative Financial Transactions (OFD) (framework, contract and confirmations).
• Reconciliation of the financial valuation of the period under review.
• Reconciliation of the inventory of transactions valued for financial and tax purposes.
• Criteria for the valuation of derivative financial instruments referred to two currencies.
• Use of exchange rates in the Official Gazette of the Federation or those to resolve obligations in the tax valuation and at their expiration.
• Exchange fluctuation of fair value or Mark to Market.
• Identification of the unpaid balances in amortizable operations throughout the instrument´s life.
• Moments of accumulation for the purposes of the provisional payment of Income Tax.
• Impacts of derivative financial transactions from the annual adjustment for inflation.
• Update of the premium on option expiration
• Impacts of derivative financial transactions in the calculation of crediting factor of the Value Added Tax.
• Impact of financial valuations on current, deferred tax and effective rate.
• Issuance of tax receipts for derivative financial transactions (OFD) and the use of their complements, payments abroad, interest payments and forex trading.
• Reporting Obligations in Annual Statement, Informative Statement on Tax Situation (DISIF) and form 76.
• Withholding obligations for payments abroad.

Derived from the recent changes and in accordance with the requirements established in the Mexican legislation and the rules of information and presentation for the fiscal year (EF) 2017, the dates of presentation of the main requirements in terms of transfer prices are the following:

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