Mexico City · +52 55 5089 8189Houston · +1 (832) 390-2700contabilidad@sinergias.pro
Mon–Fri · 9:00–19:00 (CST)
Assessment

International tax strategy in treaty jurisdictions

Mexico and seven jurisdictions with a double taxation treaty, real substance and transparency. Includes Mexico–Singapore structures.

International tax strategy

Treaty jurisdictions,structures with substance.

We structure operations and wealth in Mexico and in seven jurisdictions that have a double taxation treaty with Mexico. Every structure has a business purpose, real activity and full transparency before the authorities.

  • Treaty in forceOnly jurisdictions with a tax treaty with Mexico.
  • Real substanceOffices, people and decisions where the company sits.
  • TransparencyIdentified beneficial owners and exchange of information (CRS).
  • Corporate and wealthFor the company's operations and for the family's wealth.

Mexico

Home base

Operating and wealth base: companies, tax incentives and succession planning.

Substance
Tax domicile and operations in Mexico.
Review
Substance (Art. 69-B) and business purpose (Art. 5-A Federal Tax Code).
CorporateWealthHome jurisdiction

United States

North America

Commercial operations through an LLC or Corp., nearshoring and real estate investment.

Substance
Real operations and nexus in the state of formation.
Review
Permanent establishment, transfer pricing and FATCA.
CorporateWealthTreaty in force

Canada

North America

Trade under the USMCA and investment in North America.

Substance
Real commercial operations in Canada.
Review
USMCA rules of origin and transfer pricing.
CorporateTreaty in force

Panama

Latin America

Regional logistics hub with real operations, reviewed against preferential tax regime rules.

Substance
Office and staff in Panama.
Review
Preferential tax regimes (Title VI, Mexican Income Tax Law) and beneficial ownership.
CorporateTreaty in force

Spain

Europe

Gateway to the European Union and family wealth planning.

Substance
Effective management from Spain.
Review
Tax residence and EU anti-abuse rules.
CorporateWealthTreaty in force

Netherlands

Europe

Holding companies with real operations, trade and logistics in Europe.

Substance
Management and staff in the Netherlands.
Review
EU anti-abuse rules and beneficial ownership of dividends.
CorporateTreaty in force

Luxembourg

Europe

Regulated funds and investment vehicles.

Substance
Regulated manager and local governance.
Review
Preferential tax regimes and fund transparency.
WealthTreaty in force

Singapore

Asia-Pacific

Mexico–Singapore structures for trade and investment in Asia, with real presence in the region.

Substance
Management and operations in Singapore.
Review
Preferential regimes on passive income and CRS exchange.
CorporateTreaty in force

See required substance and review points by jurisdiction →

What we do not do

We do not design structures without economic activity, we do not conceal beneficial owners and we do not use jurisdictions to avoid reporting obligations. Every structure is reviewed against preferential tax regime rules, reportable scheme rules and automatic exchange of information.

See domestic and cross-border scope

Domestic

  • Effective tax burden reviewAnalysis of the group structure, its flows and its real effective rate.
  • Current incentives and deductionsPlan México (immediate deduction of investments and additional training deduction), IMMEX and sector incentives.
  • Restructurings with business purposeMergers, spin-offs and reorganizations that meet Article 5-A of the Federal Tax Code, with review of reportable schemes.
  • Substance and defenseFiles that support every deduction under Article 69-B and in SAT reviews.

Cross-border

  • Double taxation treatiesTax residence, permanent establishment and withholding under the treaties Mexico has signed with each jurisdiction.
  • Transfer pricingRelated-party transactions and bilingual intercompany agreements.
  • International wealth strategyStructures tailored to each client, taking into account tax residence, treaties in force, automatic exchange of information (CRS) and preferential tax regime rules.
  • Cross-jurisdiction flowsDividends, royalties, services and profit repatriation.

We work alongside licensed tax advisors in each jurisdiction.

Request an international tax assessment

Contact

Thirty minutesto know where you stand.

By the end you will know which risks exist, which solutions apply, how long they take and what they cost. If Sinergia is not the right firm, we will tell you who to call.

Mexico City+52 55 5089 8189
Houston+1 (832) 390-2700
WhatsApp+52 55 1761 5886
Emailcontabilidad@sinergias.pro
Mexico CityAv. Presidente Masaryk 111, 1st floor
Polanco V Sección, C.P. 11560
Houston, TexasTC Energy Center
700 Louisiana St., Floor 39
Houston, TX 77002
+1 (832) 390-2700

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Comprehensive privacy notice · English translation provided for convenience; the Spanish version prevails

Privacy notice

Last updated: October 4, 2026

1. Data controller

Sinergia Soluciones Empresariales GSM, S.C. ("Sinergia"), with address at Avenida Presidente Masaryk 111, 1st floor, colonia Polanco V Sección, alcaldía Miguel Hidalgo, C.P. 11560, Mexico City, is responsible for processing your personal data under the Federal Law on the Protection of Personal Data Held by Private Parties published in the Official Gazette of the Federation on March 20, 2025 (the "Law") and other applicable provisions.

2. Personal data we process

Depending on the service, we may process identification and contact data; employment and academic data; asset, financial and tax data; data on judicial or administrative proceedings to which you are a party; and information you provide about third parties related to your matter, which you represent you are authorized to provide.

In family, criminal or labor matters we may require sensitive personal data, such as health or family-life information. Such data will only be processed with your express written consent, given by handwritten signature, electronic signature or an equivalent authentication mechanism, under Article 8 of the Law.

3. Purposes

Purposes necessary for our relationship with you: responding to your assessment or contact request; checking for conflicts of interest; providing the legal, accounting, tax and compliance services engaged; representing you before authorities and courts; preparing and keeping the identification file required by the Federal Law for the Prevention and Identification of Transactions with Illicit Proceeds (LFPIORPI); invoicing and collecting fees; and complying with Sinergia's legal and tax obligations.

Additional purposes: sending you regulatory alerts, newsletters and event invitations, and assessing the quality of our services. If you do not want your data used for these purposes, you may say so at any time by writing to the address in section 6. Your refusal will not affect the services you engage.

4. Transfers and disclosures to processors

Your data may be transferred without your consent in the cases set out in Article 36 of the Law, including: to judicial, administrative or tax authorities when required by law or for the recognition, exercise or defense of a right in proceedings; to notaries, brokers, experts and correspondent lawyers in Mexico or abroad, including the United States of America, when necessary to perform the service engaged in your interest; and to companies of the same group operating under the same internal processes and policies.

We also disclose data to processors who handle it on Sinergia's behalf and under our instructions, such as Castores Digitales (BeaverGuard compliance platform) and storage, email and messaging providers. Sinergia does not sell your personal data.

5. Retention

We keep your data for as long as the professional relationship lasts and, afterwards, for the periods set by applicable law, including the ten years required by the LFPIORPI for identification files and the accounting retention periods established in the Federal Tax Code. Once those periods end, the data is securely deleted or blocked.

6. ARCO rights and withdrawal of consent

You may access, rectify or cancel your data or object to its processing (ARCO rights), and withdraw your consent or limit the use and disclosure of your data, by sending a request to contabilidad@sinergias.pro with the subject "Personal data". The request must include your name and a means to send you the response, a document proving your identity or, where applicable, legal representation, a clear description of the data and the right you wish to exercise, and any information that helps locate your data.

We will notify you of our decision within a maximum of twenty days from receipt of the request and, if it is granted, we will carry it out within the following fifteen days, under Article 31 of the Law. Withdrawal or cancellation does not apply when processing is necessary to comply with a legal obligation, such as the file retention required by the LFPIORPI.

If you believe your rights have been violated, you may file a complaint with the Secretaría Anticorrupción y Buen Gobierno, the competent authority under the Law.

7. Tracking technologies on this site

This site does not use advertising or tracking cookies. Fonts are loaded from Google Fonts, a service that may log technical data such as the browser's IP address. The assessment form does not store information on this site: it prepares a message that you decide whether to send via WhatsApp, a service subject to its own privacy policies.

8. Changes to this notice

Any change to this notice will be published in this same section of www.sinergias.pro, showing the date of the last update.

Terms of use · English translation provided for convenience; the Spanish version prevails

Terms and conditions

Last updated: October 4, 2026

1. Site owner

The site www.sinergias.pro is operated by Sinergia Soluciones Empresariales GSM, S.C. ("Sinergia"), with address at Avenida Presidente Masaryk 111, 1st floor, colonia Polanco V Sección, C.P. 11560, Mexico City. Use of the site implies acceptance of these terms.

2. Informational content

The information published is general in nature and does not constitute legal, accounting or tax advice for any specific case. Laws change often; before making decisions, consult a professional about your particular situation.

3. Professional relationship

Browsing the site, sending a message or requesting an assessment does not create an attorney-client relationship or oblige Sinergia to accept a matter. The professional relationship begins only upon signing a service proposal or engagement agreement and, where applicable, after the conflict check and the identification file required by the LFPIORPI. Please do not send confidential information before Sinergia confirms it can represent you.

4. Services in the United States

Sinergia provides services in Mexican law. Matters that require the practice of law under the laws of the United States of America or any of its states are handled in coordination with attorneys licensed in the relevant jurisdiction.

5. Intellectual property

The texts, designs, logos, trademarks and other content of the site belong to Sinergia or are used with authorization, and are protected by the Federal Copyright Law and the Federal Law for the Protection of Industrial Property. You may view and quote them for informational purposes, citing the source; any other use requires written authorization.

6. Electronic communications

Messages sent by email or WhatsApp are governed by the electronic commerce provisions of the Commercial Code. Sinergia does not guarantee receipt of messages that have not been confirmed by its staff. The fees, scope and timing of each service are set exclusively in the proposal or agreement signed by the parties.

7. Limitation of liability

Sinergia strives to keep the information on the site accurate and up to date, but is not liable for decisions made on that basis without specific advice, nor for interruptions or technical failures of the site. Links to third-party sites are provided for reference; their content and policies are the responsibility of their owners.

8. Personal data

The processing of the data you provide is governed by our privacy notice.

9. Governing law and jurisdiction

These terms are governed by the federal laws of the United Mexican States. For their interpretation and enforcement, the parties submit to the competent courts of Mexico City, waiving any other jurisdiction that may apply to them.