IMCP Examen de Certificación por Disciplinas en Tributación (ECD-TRIBUTACIÓN, Mexico)

Which constitutional provision establishes Mexicans' obligation to contribute to public expenditure in a proportional and equitable manner provided by law?

• AArticle 16 of the Constitución Política de los Estados Unidos Mexicanos
• BArticle 73, fraction VII
• CArticle 31, fraction IV
• DArticle 28, first paragraph

Which four constitutional tax principles does case law derive from Article 31, fraction IV?

• ALegalidad, proporcionalidad, equidad y destino al gasto público
• BCerteza, comodidad, economía y justicia
• CSeguridad jurídica, audiencia, irretroactividad y debido proceso
• DCapacidad contributiva, neutralidad, eficiencia y suficiencia

What does the principle of tax legality (principio de legalidad tributaria) require?

• AThat the SAT may set tax rates through the Resolución Miscelánea Fiscal
• BThat taxes may be created by presidential decree during emergencies
• CThat tax rates be approved each year by every state congress
• DThat a tax's essential elements be set in a law passed by Congress

What does the principle of tax proportionality (proporcionalidad) mean in Mexican constitutional doctrine?

• AAll taxpayers pay the same fixed amount of tax
• BEach contributes according to their contributive capacity
• CTax revenue is distributed proportionally among the states
• DTaxpayers in the same situation receive the same treatment

What does the principle of tax equity (equidad tributaria) require?

• AThat every tax apply the same rate to all activities and taxpayers
• BThat tax revenue be earmarked for public spending purposes
• CEqual treatment of equals, with differences only when justified
• DThat taxes be established only by the federal Congress

A tax reform that took effect in 2026 is applied to reopen and increase the tax on transactions a taxpayer completed in 2024, under the prior rules. Which constitutional principle is primarily at issue?

• AThe ban on retroactive laws to anyone's detriment (Art. 14)
• BThe principle of destino al gasto público (Art. 31, IV)
• CThe principle of tax equity among taxpayers (Art. 31, IV)
• DThe right to petition the authorities (Article 8)

Under Article 5 of the Código Fiscal de la Federación (CFF), how are tax provisions that impose burdens on individuals, such as those defining subject, object, base, rate or tariff, interpreted?

• ABy analogy, to close gaps in the law in favour of the treasury
• BAlways in the manner most favourable to the taxpayer
• CUnder federal common law, applied supplementarily in every case
• DStrictly; other tax provisions may use any legal method

During an audit, the SAT concludes that a series of transactions lacks razón de negocios and produced a tax benefit. Under Article 5-A of the CFF, what may it do?

• ADeclare the transactions criminally simulated without any further procedure
• BRecharacterize the acts and give them their corresponding tax effects
• CAnnul the underlying contracts under civil law
• DImpose a fine without recalculating the tax

According to Article 5-A of the CFF, when is a transaction considered to lack a business reason (razón de negocios)?

• AWhenever the transaction produces any tax saving for the taxpayer
• BWhenever the transaction involves a related party of the taxpayer
• CWhen its quantifiable economic benefit is below the tax benefit
• DWhen it is carried out with a foreign resident

Under Article 9, fraction II of the CFF, when is a legal entity (persona moral) a Mexican tax resident?

• AWhen its principal administration or effective management is in Mexico
• BOnly when all of its shareholders are Mexican nationals or residents
• CWhen it holds a bank account with a Mexican bank for its operations
• DWhen it has a permanent establishment in Mexico

Under Article 10 of the CFF, what is the fiscal domicile of a resident persona moral?

• AThe legal representative's home
• BThe domicilio social stated in the bylaws, regardless of operations
• CAny branch registered with the SAT, at the taxpayer's choice
• DThe premises where the principal administration of the business is located

A foreign resident wants to apply a reduced treaty withholding rate on income from Mexican sources. According to Article 4 of the LISR, what is required?

• ANothing; treaty benefits apply automatically to any foreign resident
• BProof of treaty residence plus compliance with treaty and LISR procedures
• CPrior authorization from the SHCP for each individual payment
• DRegistration in the Registro General de Reaseguradoras Extranjeras

Under Article 67 of the CFF, what is the general period after which the authorities can no longer determine omitted contributions (caducidad)?

• ASix months after the annual return is filed
• BThree years after the annual return is filed
• CFive years, extended to ten in specific cases
• DTwenty years in every case, with no exceptions

A taxpayer corrects an omitted payment on its own initiative before any audit order, request or other authority action has been notified. Under Article 73 of the CFF, what is the consequence?

• ANo fines are imposed, although tax, actualización and recargos are due
• BThe omitted tax and all of its accessories are waived entirely
• CThe taxpayer must still pay a fine equal to 55% of the omitted tax
• DThe payment is treated as late, and a criminal complaint follows automatically

Under Article 26 of the CFF, which person may be jointly liable (responsable solidario) for a company's tax debts?

• AAny customer who bought goods or services from the company
• BAny employee who appears on the company's payroll
• CThe external bank that provides the company's accounts
• DIts directors, if the company commits certain listed failures

Which set lists the fundamental principles in the IMCP's Código de Ética Profesional, which follows the IFAC international code?

• ALegalidad, proporcionalidad, equidad y destino al gasto público
• BIntegridad, objetividad, competencia y diligencia, confidencialidad y comportamiento
• CHonestidad, diligencia, imparcialidad, probidad, buena fe e independencia de criterio
• DIndependencia, rentabilidad, lealtad al cliente y reserva profesional

A client asks its tax adviser to deduct invoices from a supplier that the adviser knows has no staff or assets to provide the services described. What does professional ethics require?

• ADeduct the invoices, because the CFDIs validate in the SAT portal
• BDeduct them and add a disclaimer to the engagement letter
• CRefuse, explain the risks and withdraw if the client insists
• DDelegate the preparation of the return to a junior staff member

Under the principle of professional competence and due care, what must a tax practitioner do?

• AKeep up to date with the law and work diligently to professional standards
• BAccept any engagement, even outside one's expertise, to keep the client
• CRely on the technical knowledge gained at university
• DGuarantee the client a favourable outcome in any tax dispute

A tax adviser's firm would receive a large success fee if a position it recommended is sustained. Which fundamental principle is most directly threatened, and what should the adviser do?

• AConfidentiality; the adviser should stop documenting the analysis
• BCompetence; the adviser should hand the file to the client's lawyer
• CIntegrity; the adviser must decline all fees from the client
• DObjectivity; assess the self-interest threat and apply safeguards

A prospective client asks a CPC for details of another client's tax planning to replicate it. What does the principle of confidentiality require?

• AShare the information, provided the other client's name is removed
• BKeep it confidential unless authorized or legally required to disclose
• CShare it, but only with other members of the IMCP
• DShare it freely once the other engagement has ended

Under Article 9 of the Ley del Impuesto sobre la Renta (LISR), what rate applies to the resultado fiscal of personas morales in the general regime?

• A16%
• B30%
• C25%
• D35%

A general-regime persona moral has, for 2026, ingresos acumulables of MXN 12,000,000, deducciones autorizadas of MXN 8,000,000, PTU paid in the year of MXN 500,000 and pending tax losses of MXN 500,000. What are its resultado fiscal and annual ISR?

• AResultado fiscal MXN 4,000,000; ISR MXN 1,200,000
• BResultado fiscal MXN 3,500,000; ISR MXN 1,050,000
• CResultado fiscal MXN 2,500,000; ISR MXN 750,000
• DResultado fiscal MXN 3,000,000; ISR MXN 900,000

A general-regime company is preparing its 2026 monthly ISR payments. Under Article 14, fraction I of the LISR, how does it compute the coeficiente de utilidad?

• APrior year's utilidad fiscal divided by that year's ingresos nominales
• BTotal sales divided by total expenses for the current month of payment
• CThe previous year's ISR divided by its accounting profit before taxes
• DThe resultado fiscal after tax losses, divided by total assets

In 2025 a company had a utilidad fiscal of MXN 1,500,000 on ingresos nominales of MXN 10,000,000. From January to April 2026 its cumulative ingresos nominales are MXN 4,000,000, with no prior payments, losses or PTU to apply. What provisional ISR is computed for April?

• AMXN 600,000
• BMXN 45,000
• CMXN 180,000
• DMXN 1,200,000

A company pays PTU in May 2026. Under Article 14, fraction II of the LISR, how is that PTU reflected in its 2026 provisional ISR payments?

• AIt is deducted in full from the May provisional payment only
• BIt is subtracted in equal parts in the May–December payments
• CIt cannot be taken into account until the annual return
• DIt is spread over January–December by amending earlier payments

Which of the following is an authorized deduction for a persona moral under Article 25 of the LISR?

• AThe ISR payable by the company itself
• BFines and surcharges imposed by the authorities
• CDividends paid to shareholders
• DCost of goods sold (costo de lo vendido)

What is the first general requirement for an authorized deduction under Article 27, fraction I of the LISR?

• AIt must be strictly indispensable for the taxpayer's activity
• BIt must be paid in cash so that it can be deducted immediately
• CIt must exceed MXN 2,000 in a single payment to the supplier
• DIt must be approved by the shareholders' meeting

Under Article 27, fraction III of the LISR, above what amount must an expense be paid by transfer, nominative check, or credit, debit or services card to be deductible?

• AMXN 500
• BMXN 5,000
• CMXN 2,000
• DMXN 50,000

A company buys MXN 900 of fuel for its delivery vehicles and pays in cash. Is the expense deductible under Article 27, fraction III of the LISR?

• AYes, because the payment is below MXN 2,000
• BNo, fuel must always be paid by electronic means
• CYes, provided the fuel station issues a CFDI
• DOnly 50% of the expense is deductible

How is the tax deduction for fixed-asset investments generally calculated under Articles 31 to 35 of the LISR?

• A100% in the year of purchase, for every type of fixed asset
• BAccording to the useful life estimated under the NIF for accounting
• COnly when the asset is eventually sold or written off
• DStatutory annual rates applied to the MOI, updated for inflation

A company buys a cargo truck (camión de carga) with a MOI of MXN 400,000 in January 2026. Article 34, fraction VI of the LISR sets 25% for automobiles, buses and cargo trucks. What is the annual deduction before inflation updating?

• AMXN 100,000
• BMXN 43,750
• CMXN 175,000
• DMXN 200,000

Under Article 36, fraction II of the LISR, up to what MOI is investment in automobiles deductible?

• AMXN 130,000 for all vehicles, whatever their type
• BMXN 500,000 for combustion-engine cars
• CMXN 175,000; MXN 250,000 for electric or hybrid cars
• DThere is no cap on the deductible investment

What is the main tax effect of distributing dividends from the balance of the cuenta de utilidad fiscal neta (CUFIN)?

• AIt is fully exempt at every level, including the 10% withholding for individuals
• BThe company pays no further corporate ISR, because those profits were already taxed
• CThe dividend becomes a deductible expense for the distributing company
• DThe company must pay 30% ISR again on the grossed-up amount of the dividend

Under Article 77 of the LISR, which item increases a company's CUFIN balance?

• ACapital contributions received from shareholders during the year
• BDividends paid to shareholders out of the CUFIN balance
• CDividends received from other personas morales resident in Mexico
• DThe ISR paid for the year under Article 9

What is the cuenta de capital de aportación (CUCA) used for under Article 78 of the LISR?

• ATo let returned capital be distributed without being taxed as a dividend
• BTo record the stock options granted to executives and their exercise
• CTo control the monthly provisional ISR payments made during the year
• DTo register the credits for foreign taxes paid on foreign income

A Mexican company pays dividends to a resident individual shareholder. What additional ISR applies under Article 140 of the LISR?

• ANone, because the company has already paid ISR on those profits
• BA 35% withholding that the shareholder credits against the annual return
• CAn additional 10% definitive tax, withheld by the distributing company
• DA 30% tax paid by the shareholder only if the dividend exceeds MXN 1,000,000

How does the ajuste anual por inflación under Article 44 of the LISR work for a persona moral?

• AAnnual sales are multiplied by the year's inflation rate to get the adjustment
• BAverage debts are compared with average credits, times the inflation factor
• CTotal assets are divided by the general minimum wage for the year
• DA fixed inflation deduction is taken each year

Under the thin-capitalization rule of Article 28, fraction XXVII of the LISR, when is interest non-deductible?

• AWhenever the interest is paid to any bank, domestic or foreign
• BWhen the interest is paid in cash rather than by transfer
• CWhenever the lender is located in North America
• DWhen foreign related-party debt exceeds three times equity

Under Article 28, fraction XXXII of the LISR, how are net interest expenses limited?

• ANet interest above 30% of adjusted fiscal profit is non-deductible
• BAll interest expense is capped at 10% of the company's annual sales
• CInterest is deductible only for banks and other financial institutions
• DThere is no limit on interest deductions

Which inventory valuation method is not among those Article 41 of the LISR allows for cost of goods sold?

• APrimeras entradas primeras salidas (PEPS)
• BCosto identificado
• CÚltimas entradas primeras salidas (UEPS)
• DCosto promedio

Under Article 57 of the LISR, for how many years can a persona moral carry forward a tax loss?

• AFive years after the year of the loss
• BTen years after the year of the loss
• CIndefinitely, with no time limit
• DOnly in the year immediately following

A company had enough fiscal profit in 2025 to absorb a prior loss but did not apply it. What does Article 57 of the LISR provide?

• AIt may still apply the full loss in any later year within the ten-year period
• BIt must file an amended 2025 return within 30 days to apply the loss
• CThe unapplied portion of the loss is refunded to the company in cash
• DIt loses the right to apply the loss later, up to what it could have used

According to Article 9 of the LISR, how is the base for employees' profit sharing (PTU) determined?

• ATaxable income minus deductions, without subtracting PTU paid or losses
• BThe company's accounting net profit determined under the NIF
• CThe company's gross revenue for the year, before any deductions
• DThe resultado fiscal, after subtracting tax losses

Since the 2021 labour reform, what does Article 127, fraction VIII of the Ley Federal del Trabajo provide about each worker's PTU amount?

• ANo limit applies to the PTU an individual worker may receive
• BIt is limited to one month of the worker's current salary
• CThree months' salary or the prior three-year average, whichever is higher
• DIt is limited to MXN 50,000 per worker per year

Under Article 28, fraction XXX of the LISR, what portion of payments that are also exempt income for the worker (such as the exempt part of the aguinaldo or savings fund) is non-deductible for the employer?

• A0%
• B47%, or 53% if the employer reduced the exempt benefits compared with the prior year
• C100%
• D53%, or 47% if the employer did not reduce the exempt benefits compared with the prior ye…

What standard must transactions between related parties meet under Articles 76 and 179 of the LISR?

• APrices must be set below cost to avoid double taxation
• BRelated-party transactions are prohibited
• CPrices are set freely by the controlling shareholder
• DArm's length: terms independent parties would agree

Which transfer pricing method does Article 180 of the LISR list first, to be applied first as the law requires?

• AMétodo de precio comparable no controlado (CUP)
• BMétodo de márgenes transaccionales de utilidad de operación
• CMétodo de partición de utilidades
• DMétodo residual de partición de utilidades