Derived from the recent entry into force of the Simplified Trust Regime (RESICO), Various problems and questions have arisen, so we put on the table the considerations that legal persons should have (PM) forced to change the regime or, being so, they are out of the assumption due to the restrictions that the legislation itself marks.

Antecedent. PMs made up of natural persons only, will be obliged to pay taxes in a RESICO, when in the immediately preceding financial year they had obtained income that did not exceed the 35 mdp; Nevertheless, there are restrictions that can remove these PM from the regime, Therefore, the following should be taken into consideration:

• high in the regimen. automatically, the authority has registered several taxpayers in the regime, contemplating the information in their databases (3.13.27. RMF). In this situation, there will be taxpayers, by the restrictions imposed by the regime itself, by the restrictions imposed by the regime itself.

by the restrictions imposed by the regime itself, by the restrictions imposed by the regime itself, by the restrictions imposed by the regime itself (by the restrictions imposed by the regime itself) by the restrictions imposed by the regime itself, by the restrictions imposed by the regime itself, by the restrictions imposed by the regime itself, by the restrictions imposed by the regime itself.

• by the restrictions imposed by the regime itself. by the restrictions imposed by the regime itself, by the restrictions imposed by the regime itself, by the restrictions imposed by the regime itself. by the restrictions imposed by the regime itself, by the restrictions imposed by the regime itself, to validate that they are duly manifested or, in your case, present a case of clarification in Mi Portal to make it known to the authority and correct said situation.

• Non-deductible expenses. Within the authorized deductions of the PM civil societies, are the advances of remnants delivered to their partners. Although for the general regime of the PM this concept is still contemplated as a deduction, This is not the case for PMs obliged to pay taxes in RESICO., because it is not included in any of the seven fractions of the article 208 of the Income Tax Law, before which, the Taxpayer Defense Office, issued a statement in the news of its website, in which it is indicated that the SAT proceeded to confirm if indeed said items are not deductible or if there would be any clarification, Nevertheless, the authority replied that there is no explanation and, implicitly, the non-deductibility of said concept is confirmed.

In these situations, we believe that it is more important to be vigilant of the tax situation of each taxpayer and constantly validate their tax situation so that, in case there is any discrepancy, appropriate measures are taken.

We remain at your service for any questions or comments regarding the particular.

DFK-MEXICO

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Corporate entities that will not be able to pay taxes in RESICO

(third paragraph, Article 206 of the LISR)

They will not be taxed under the Simplified Trust Regime:

I. legal persons when one or more of its partners, shareholders or members, participate in other commercial companies where they have control of the company or its administration, or when they are related parties in the terms of article 90 of this Law.

For purposes of the previous paragraph, control will be understood, when one of the parties has effective control over the other or that of its management, to such an extent that it can decide the moment of distribution or distribution of income, profits or dividends from them, either directly or through an intermediary.

II. Taxpayers who make activities through trust or joint venture.

III. Those who pay taxes in accordance with Chapters IV, Those who pay taxes in accordance with Chapters IV, Those who pay taxes in accordance with Chapters IV (Those who pay taxes in accordance with Chapters IV, Those who pay taxes in accordance with Chapters IV, Those who pay taxes in accordance with Chapters IV, Those who pay taxes in accordance with Chapters IV).

Those who pay taxes in accordance with Chapters IV. Those who pay taxes in accordance with Chapters IV (Those who pay taxes in accordance with Chapters IV).

Those who pay taxes in accordance with Chapters IV. Those who pay taxes in accordance with Chapters IV.