Mexico’s tax reform, enacted on 9 December 2019, significantly affects nonresident entities that conduct operations in Mexico through unrelated parties under the IMMEX program in the “albergue” or shelter regime, which are commonly referred to in Mexico as shelter companies. For more information on the tax reform, see EY Global Tax Alerts, Mexican Congress passes tax reform for 2020, dated 5 November 2019 and Mexican tax reform for 2020 enacted, dated 9 December 2019.BackgroundThe tax reform includes various provisions aimed at improving the tax authorities’ tax collection tools and limiting some deductions or expanding the tax base.For the export manufacturing industry, the...