On 18 September 2019 the Mexican Federal Official Gazette published the Decree by means of which the Convention between the United Mexican States and the Government of the Republic of Indonesia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion in Income Tax Matters is amended (the “Decree”).
The main amendment is reflected in Article 26 “Exchange of Information”, in which it is established that if a Contracting State requests information pursuant to this Article, the other Contracting State shall employ any measures necessary to gather the requested information, even if the other State does not necessarily require said information for its own tax purposes.
Although the preceding obligation is subject to the limitations of paragraph 3 of Article 26 (which in general terms are not amended), in no case shall such limitations be interpreted to allow a Contracting State to refuse to grant the information solely because it does not have an internal interest in obtaining such information, or if it is held by a bank, another financial institution, agent or an individual acting as a representative or trustee.
It should be noted that the Decree entered into force on the same date of its publication in the Mexican Federal Official Gazette
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