TMI BlogTERMINATIONX X X X Extracts X X X X X X X X Extracts X X X X ..... is given; and ( ii ) with respect to taxes on income for any fiscal year beginning on or after 1st April of the calendar year next following that in which the notice of termination is given; and in respect of income derived in any fiscal year beginning on or after the first day of April next following the calendar year in which the notice of termination is given; and ( b ) In Mexico : ( i ) in respect of taxes withheld at source, to income paid or credited on or after 1st January in the calendar year next following that in which the notice of termination is given; and ( ii ) in respect of other taxes, for taxable year beginning on or after 1st January in the calendar year next following that in which the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the same or similar kind of goods or merchandise as those which are usually sold through that permanent establishment, these goods or merchandise shall be considered as sold through that permanent establishment. However, the profits derived from such sales shall not be taxable in the other Contracting State if the enterprise demonstrates that such sales have been carried out for reasons other than obtaining a benefit under this Agreement. III. Ad. Article 8 In respect of Article 8, if the place of effective management of a shipping enterprise is aboard a ship, then it shall be deemed to be situated in the Contracting State in which the home harbour of the ship is situated, or, if there is no such home harbour, in the Contract ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ons of Article 13, the term "royalties" also includes payments derived from the alienation of any such right or property which are contingent on the productivity, use or disposition thereof. VI. It is clarified that the provisions of this Agreement shall not prevent a Contracting State from applying its provisions of domestic law- regarding thin capitalization, controlled foreign corporation (in the case of Mexico, preferential tax regimes) and back to back loans, whether existing on the date of entry of force of this Agreement or enacted subsequently. VII. It is understood that for Mexican tax purposes, the fixed base will be treated in accordance with the principles that apply to permanent establishment. IN WITNESS WHEREOF the unde ..... X X X X Extracts X X X X X X X X Extracts X X X X
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