The Federal Tax Code establishes the obligation to disclose information in accordance with the recommendations of this Action. The main objective is to increase transparency by providing tax authorities with timely information about potentially aggressive schemes and abusive tax planning. This will allow them to identify the taxpayers who implement them and the advisors who promote them, and thus detect schemes that exploit the vulnerabilities of the tax system, generating a deterrent effect.

A disclosure regime was incorporated for reportable schemes in Mexico, that is, those schemes that generate or may generate, directly or indirectly, a tax benefit in Mexico and have any of the characteristics identified as risk areas (tax reduction, deferral, non-payment of taxes, etc.). This will provide information on issues that the tax authorities have identified as risk areas.

Some examples of reportable schemes are those that:

1. Involve a foreign resident applying a double taxation agreement signed by Mexico with respect to income not taxed in the taxpayer's country or jurisdiction of tax residence.

2. Involve the transfer of intangible assets that are difficult to value.

3. Involve corporate restructurings in which there is no consideration for the transfer of assets, functions, and risks, or taxpayers reduce their operating profit by more than 20%.