U.S. and Mexico: A Tax and Economic Landscape That Dema

This cross-border alliance, led by Jose Padilla, Tax & Legal Partner at Kreston BSG, and Randall Cathell, International Tax Director at CBIZ, promotes a cooperative, bilateral, and strategic approach to delivering effective guidance for clients on both sides of the border.

Bilateral Opportunities and Challenges

• Foreign Direct Investment (FDI): Since 1999, the United States has invested over US $328 billion in Mexico, while Mexican outbound investment in the U.S. exceeds US $5 billion annually. Key sectors include auto parts, energy, food, and real estate.

• Nearshoring: Mexico continues to position itself as one of the world’s top destinations for operational relocation. Industry leaders such as JPMorgan (1) and Barclays (2) highlight the country’s strong infrastructure, skilled workforce, and favorable legal framework under the USMCA. Despite global uncertainty and the impact of cross-border tariffs, Mexico remains well-positioned to benefit from this trend. At Kreston BSG, we help businesses assess risks and maximize nearshoring opportunities strategically.

• Tax Digitalization: Mexico and the U.S. are at different stages of tax technology maturity. Mexico has made significant advances in electronic invoicing and real-time reporting, while the U.S. maintains leadership in digital taxpayer services, despite ongoing challenges in e-invoicing adoption.

A Constantly Evolving Tax Framework

• Tax Reforms: While the U.S. is considering major changes to its tax regime (Pillar 2, GILTI, BEAT), Mexico remains focused on digital audits, economic substance, and beneficial ownership verification.

• Transfer Pricing and International Treaties: Both countries enforce complex regulations on intercompany transactions and reportable arrangements, requiring comprehensive advisory to prevent double taxation and manage potential tax disputes.

• Key Differences in Interpretation: Mexico follows the Vienna Convention and OECD standards, whereas the U.S. relies on technical explanations and domestic law. These differences can lead to challenges in income classification, treaty application, and anti-abuse analysis.

Our Value Proposition

At Kreston BSG, as independent members of Kreston Global, with presence in over 115 countries, and together with our strategic partners at CBIZ (U.S.), we offer coordinated solutions that include:

• Cross-border tax and legal structuring

• Transfer pricing advisory and audit defense

• Tax treaty interpretation and dispute prevention

• Advisory on foreign investment, dividend repatriation, and BEPS compliance

Conclusion

The tax landscape between Mexico and the United States is dynamic, challenging, and filled with strategic opportunities. At Kreston BSG, backed by our international network and in close cooperation with CBIZ, we have the capacity, technical expertise, and practical experience to be your trusted advisory firm for international tax matters.

Do you have operations in the U.S. or international clients? Let’s talk.

Sincerely,
Kreston BSG Mexico

(1) - Jamie Dimon, CEO of JPMorgan Chase, highlighting Mexico as a leading nearshoring destination, citing its strenghts in infraestructure, education, and energy.

November 17, 2023 - during an interview with El Financiero Bloomberg TV, where he described Mexico as a global leader in nearshoring and investment.

(2) Gabriel Casillas, chief Economist for Latin America at Barclays

April 19, 2024 - commmenting on Mexico's economic momentum from nearshoring and infraestructure development.