Mexico: Guidelines under “Fibra E” regime | KPMG | GLOBAL

Mexico: Guidelines under “Fibra E” regime; energy and infrastructure projects

Mexico: Guidelines under “Fibra E” regime

Mexico’s tax administration issued guidelines concerning entities (fideicomisos or “trusts”) that invest in energy and infrastructure projects under the energy reform incentive regime known as “Fibra E.”


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The guidelines were published in the official journal on 1 April 2016, and list activities of companies that may qualify for Fibra E benefits—in general, activities relating to oil and petrochemical products.

Under the incentive regime, there is a requirement that at least 90% of the taxable income is from the subject activities.

The guidelines clarify the treatment of revenue derived from the sale of land and investments, and the relationship of these assets in the development of approved activities. The guidelines also address the treatment of:

  • New non-monetary assets
  • Allowable deductions
  • Capital contributions
  • Sales of shares, contribution of shares
  • Other items


Read an April 2016 report (Spanish) [PDF 68 KB] or (English) [PDF 40 KB] prepared by the KPMG member firm in Mexico: Fibra E

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