Income Tax Law

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INCOME TAX LAW

In the margin, a seal with the National Coat of Arms and the legend “United Mexican
States. Office of the President of the Republic

VICENTE FOX QUESADA, Constitutional President of the United Mexican States, to its
inhabitants, know ye:

That the Honorable Congress of the union has been pleased to direct to me the following:

DECREE

The General Congress of the United Mexican States, decrees:

INCOME TAX LAW
(Published in the Official Daily of the Federa l Government for January 1st. and list of
errata on January 24, 2002)

TITLE III

Regime for Non-profit Entities

Tax regime[1] ARTICLE 93. The entities referred to in Ar ticle 95 and 102 hereof, and also investment
companies specializing in retirement funds, sha ll pay no Income Tax except as provided in
Article 94 thereof. Their participants shall on ly consider as distributable remainder the
revenues delivered to them in cas h or in kind by said entities.

Investment corporations [2] The provisions of this Title shall also be applicable to the investment companies referred to
in the Investment Companies Act except those referred to in Article 50 hereof. Members or
shareholders of the investment companies refe rred to in this paragraph shall be taxpayers
hereunder.

Distributable remainder[3] The entities referred to in this Article shall determine the distributable remainder for the
calendar year of its members or shareholde rs by subtracting the deductions authorized
under Title IV hereof from the revenues obtaine d in the period (except those indicated in
Article 109 hereof and those on which the final tax has been paid).

Participants or shareholders of entities[4] When the majority of the participants or shar eholders of such entities are taxpayers under
Title II hereof, the distributable remainde r shall be computed by adding the revenues
applicable and subtracting the deductions ap plicable thereunder. When said majority
consists of taxpayers under Part I or II of Ch apter II of Title IV hereof, the distributable

remainder shall be computed by adding the revenues and subtracting the deductions as
applicable under said Part.

Refunds of contributions[5] The participants or shareholders of the entities referred to in this Title shall not consider
that said entities’ refunds of contributions made by them are revenues. The provisions of
Article 89 hereof shall be observed for said purposes.

Taxed revenues[6] If the entities referred to in th is Title alienate goods not incl uded in their fixed assets or
render services to persons othe r than their members, the tax on profit from revenues from
the activities referred to in Title II hereof shall be at the rate of Article 10 hereof when such
revenues exceed 5% of the total revenues of the entity in the then current fiscal year. The
provisions of this paragraph shall not be a pplicable to entities authorized to obtain
deductible donations pursuant to Section I of Article 31 and Section III of Article 176
hereof.

Revenues that are taxed[1] ARTICLE 94. The entities referred to in this Title (excepting those mentioned in Article
102 hereof and also excepting investment companies specializing in retirement funds and
entities authorized hereunder to receive deductible donations) shall pay Income Tax on
their revenues of the nature referred to in Chapter IV, VI, and VII of Title IV hereof,
regardless of those referred to in Chapter VI hereof being obtained in foreign currency. The
provisions of said Title shall be applicable for said purposes , and amounts withheld, if any,
shall have standing as final payments.

Investment companies[2] Neither the debt-investment nor the variable-y ield investment companies referred to in
Article 103 hereof shall pay ta x hereunder on their revenues de scribed in Chapter VI of
Title IV hereof. Said companies and their members or shareholders shall observe the
provisions of Articles 103, 104 y 105 thereof.

Persons who are not taxpayers[1] ARTICLE 95. The following persons, in addition to those listed in Article 102 hereof, shall
be deemed non-profit entities:

I. Unions of workmen, and organizati ons in which such unions are grouped.

II. Associations of employers.

III. Chambers of commerce and industry; groups of farmers, stockmen, fishermen, or
silviculture and the organizations into which they assemble.

IV. Collegiate bodies of professionals, and the organizations into which they are grouped.

V. Civil associations and limited liability societies for purposes of public interest
performing decentralized management of irrigation districts or units upon prior concession
or permit.

VI. Welfare or beneficent in stitutions duly authorized by th e laws governing such matters,
and also non-profit civil socie ties or associations authorized hereunder to receive donations
and having low-income persons, sectors or regi ons as their beneficiaries, or conducting
activities to improve subsistence and devel opment conditions for indigenous communities
or for groups rendered vulnerable by virtue of age, sex or problems of incapability, and
engaging in the following activities:

a) Attention to requirements of basic subsistence in matters of food, clothing or lodging.

b) Medical attendance or medical rehabi litation, or attendance in specialized
establishments.

c) Legal assistance, support or promotion of protection of the rights of minors or the social
readaptation of offenders.

d) Rehabilitation of alco holics and drug addicts.

e) Assistance for funeral services.

f) Social or educational or ientation or work training.

g) Promotion of organized participation in acts improving the condition of the community.

VII. Cooperative consumption societies.

VIII. The organizations, whether of producer or consumers, into which cooperative
societies are grouped under law.

IX. Mutual societies which do not operate with third parties, provided, that they do not
incur in expenses such as premiums, commissi ons or other similar items, for acquisition of
business.

X. Civil societies or associations engagi ng in teaching and possessing authorization or
acknowledgment of official valid ity of studies in the terms of the General Education Act,
and also institutions created by presidential decree or by law and having teaching as their
purpose.

XI. Civil societies or associations engaging in scientific or technological research and duly
recorded in the National Registry of Sc ientific and Technological Institutions.

XII. Non-profit civil associati ons or societies authorized to receive donations and engaging
in the following activities:

a) Promotion and diffusion of music, plastic arts, dramatic arts, dance, literature,
architecture or cinematography under the Law creating the National Institute of Beaux Arts
and Literature or the Federal Law of Cinematography.

b) Support of artistic, educational and resear ch activities, in accordance with the next
preceding Subsection.

c) Protection, conservation, restoration and recovery of the Na tion’s cultural patrimony, as
provided in the National Law on Archeological, Artistic and Historical Monuments and the
General Law of National Assets; or the ar t of indigenous communities in all primary
manifestations of their own languages, uses and customs, artisanry and traditions of the
plurality of cultural compositions comprising this country.

d) Installation on establishment of libraries included in the National Network of Public
Libraries, in accordance with the General Libraries Act.

e) Support of the activities and objectives of museums depending on the National Council
for Culture and the Arts.

XIII. Civil institutions or societies organized for the sole purpose of managing savings
funds or boxes, and those referred to in the labor legislation, and also the savings and loan
cooperatives referred to in the Popular Savings and Credit Act.

XIV. Associations of parents duly organized a nd registered in terms of the Regulations for
Associations of Parents of the Federal Education Act.

XV. Collective management associations or ganized in terms of the Federal Law of
Copyright.

XVI. Civil associations or soci eties organized for political, sporting or religious purposes.

XVII. Civil associations or societies which grant scholarships, as referred to in Article 98
hereof.

XVIII. Civil associations of colonos, and civi l associations engaged exclusively in the
management of a property under the regime of condominium.

XIX. Non-profit civil societie s and associations organized and operating solely for
activities of investigation or preservation of wild land or aq uatic flora or fauna in the
specific geographic areas specified in gene ral rules issued by the Tax Administration
Service, and those organized and operating for the sole purpo se of promoting prevention
and control of water, air a nd soil contamination, protection of the environment, and
conservation and restoration of ecological equilibrium among the general public. Said
societies or associations shall require to comply with the requisites of Section II, III, IV and
V of Article 97 hereof to be deemed au thorized hereunder to receive donations.

XX. Non-profit civil associations and societies evidencing engaging exclusively in
reproduction of protected and endangered specie s and conservation of the habitat thereof,
provided, that, in addition to complying with such general rules as are issued by the Tax
Administration Service, they obt ain the prior opinion of the Ministry of the Environment
and National Resources. Said asso ciations and societies shall comply with the requisites of
Section II, III, IV and V of Article 97 hereof.

Distributable remainder[2] The entities referred to in Sections V, VI, V II, IX, X, XI, XIII, XVI, XVII, XVIII, XIX and
XX of this Article, and the investment companie s referred to in this Title shall consider
distributable remainder (regardle ss of their not having delivered it in cash or in kind to their
participants or shareholders) the amounts of revenues omitted or purchases not made but
unduly recorded; their disbursements which are not deductible in the terms of Title IV
hereof (except when said circumstance is due to failure by such disbursements to comply
with Section IV of Article 172 hereof); and loans to their partners or participants, or to the
spouses or direct ascendants or descendants of the former or the latter (except to partners or
participants in the Savings and Loan coopera tives referred to in Section XIII of this
Article). The amounts of loans deemed distributable remai nder in the terms of this
paragraph shall be subtracted from the distributable remainders distributed by the entity to
its partners or participants.

Tax of entities[3] If a distributable remainder as provided in th e next preceding paragraph is determined, the
entity concerned shall pay over as tax to its charge that determined by applying thereto the
maximum rate applicable to the excess over the lower limit established in tax tariff of
Article 177 hereof, and said tax shall in such case be deemed final and be paid over on or
before February of the year next following th at in which any of the contingencies referred
to in said paragraph occurs.

Foundations and others[1] ARTICLE 96.- Foundations, associations of patrons, and other entities the purpose of
which is to grant financial s upport to the activities of entities duly authorized hereunder to
receive deductible donations may obtain deduc tible donations, provided, that they comply
with the following requisites:

I. That they apply the total amount of revenue s to the purposes for which they were created.

II. That on the occasion of their liquidation, they apply the total amount of their patrimony
to entities authorized to receive deductible donations.

Requisites[2] The requisites established in this Article shall be set forth as irrevocable in the charter of
the entity concerned.

Deductible donations[1] ARTICLE 97.- The entities that are not taxpayers, as referred to in Sections VI, X, XI and
XII of Article 95 hereof, sha ll require to comply with the following in order to be
considered institutions authorized to rece ive deductible donations in terms hereof:

Organization and operation
I. That they be organized and operate excl usively as entities engaging in any of the
activities referred to in Sections VI, X, XI and XII of Article 95 hereof and that, as
provided in such general rules as the Tax Administration Service shall issue for the
purpose, they receive a substant ial part of the revenues from funds furnished by the Federal
Government, the States or municipalities, from donations, or from attainment of their
corporate purposes. Entities in whose favor an authorization to receive donations deductible
abroad in pursuance of interna tional treaties has been issued shall require to comply with
the foregoing and shall not receive excessive amounts of revenues from leases or as
interest, dividend or royalties or from activities not related with their corporate purpose.

Purpose of the activity
II. That the activities they develop have as primary purpose the attainment of the purposes
for which they were organized; provided, how ever, that they shall not be entitled to
intervene in political campaigns or to beco me involved in activities of propaganda or
intended to influence legislation.

Publication of an analysis or a research not of a proselyting na ture, or provision of technical
assistance to a governmental agency having ma de written request therefor shall not be
deemed to influence legislation.

Destine of assets
III. That they destine their assets exclusively to purposes appropriate to that for which they
were organized; provided, however, that they shall grant no benefit on the distributable
remainder to any individual whatsoever or to their participant or partner individuals or
entities except, in the case last mentioned, an entity of the nature referred to in this Article,
or when the case be of remunerati on for services actually received.

Liquidation
IV. That upon and by virtue of their liquidation, the total of their patrimony be applied to
entities authorized to r eceive deductible donations.

Public information
V. That they maintain availabl e to the general public throughout the period and in the terms
established through rules of a general nature by the Tax Administration Service, the
information relative to authorization to re ceive donations and that relative to their
compliance of their tax obligations.

Charter of the entity[2] The requisites referred to in Sections III and IV of this Article are to be established with
standing as irrevocable in the ch arter of the entity concerned.

Administrative control[3] Authorized donees are in all cases to comply with such requisites of administrative control
as the Regulations hereof may establish for the purpose.

Granting of scholarships
ARTICLE 98.- Civil associations or societies organized in order to grant scholarships may
obtain authorization to receive deductible donations, provided, that they comply with the
following requisites:

I. That said scholarships be granted for st udies at institutions of learning possessing
authorization or acknowledgment of official validity of studies pursuant to the General
Education Act or, in cases of foreign institutions, they be acknowledged by the National
Council of Science and Technology.

II. That the scholarships be gr anted through competitions that are open to the general public
and be assigned with basis on objective data related with the academic capability of the
candidate.

III. That they comply with the requisites of Sec tions II, III, IV and V and with those of the
penultimate and final paragr aphs of Article 97 hereof.

Programs of school enterprise[1] ARTICLE 99.- Programs of school enterpri se established by institutions possessing
authorization of the tax authority shall be taxpayers of this tax, and the institution
establishing the program shall be jointly liable therefor.

Required authorization[2] Said programs may obtain authorization to incorporate as independent entities and shall in
such case consider the occasion of obtention of said authorization as that of initiation of
their activities.

Provisional payments[3] The Tax Administration Service shall establ ish, through rules of a general nature, the
formal obligations and the manner of making of provisional payments, so long as said
enterprises are considered within the programs of school enterprise.

Obtention of deductible donations[4] The programs of school enterprise referred to in this Article may obtain authorization to
receive donations that will be deductible from Income Tax, provi ded, that they comply with
the requisites referred to in Sections II, II I, IV and V and in the penultimate and last
paragraphs of Article 97 hereof.

Variable-yield investment companies [1] Article 100. Variable-yield investment comp anies distributing dividends obtained from
other companies shall keep an account of net dividends for purposes of Articles 93 and 104
hereof.

Net dividend account[2] The account referred to in this Article shall consist of the dividends received from other
entities residing in Mexico and shall be decr eased by the amount of dividends paid from
said account to its participants. Neither di vidends in shares nor those reinvested in
subscription or increases of cap ital stock of the same person distributing them, in the term
of thirty days next following distribution thereof, shall be included fo
r purposes of this
Article. The balance of the account provided for in this Article shall be updated in terms of
Article 88 hereof.

Sundry obligations[1] ARTICLE 101.- The entities referr ed to in this Title shall have the following obligations in
addition to those establishe d in other Articles hereof:

Accounting
I. To keep the accounting systems pursuant to the Federal Tax Code, the Regulations
thereof and the Regulations hereof, and to ma ke therein entries of their transactions.

Documents evidencing sales
II. To issue documents complying with the requi sites established in the applicable fiscal
provisions, in evidence of the alienations they make, the services they render, or their grant
of temporary use or advantage of assets, and to keep copies thereof available to the tax
authorities.

Annual return
III. To file at an authorized office not later than February 15th of every year a return
showing the distributable remainder and the proportion thereof corresponding to each
participant.

Evidence to participants
IV. To furnish to their participants, not later th an February 15th of the next following year,
evidences indicating the am ount of such remainder as may be distributable.

Withholding of taxes
V. To issue the evidences and furnish the info rmation referred to in Sections III and VIII of
Article 86 hereof; to withhold and pay over th e tax due by third parties and to require
documents complying with the fi scal requisites, when they make payments to third parties
and are obligated thereto here under. When they make payments which are also revenues
pursuant to Chapter I of Title IV hereof, they shall also comply with the obligation referred
to in Article 118.

Additional information on yearly return
VI. File the following information on or before 15 February of each year:

a) On all persons having withheld Income Tax from them in the next preceding calendar
year, and on all foreign residents to whom they have made payments as provided in Title V
hereof.

b) On all persons to whom they have made donations in the next preceding calendar year.

(2) Accounting on electronic means
When the entity concerned keeps its accounting th rough a system of electronic registers, the
information referred to in the preceding Subsec tions shall be furnished on magnetic devices
processed in the terms establ ished through general rules by the Tax Administration Service.
The tax authorities shall return said devices to the taxpayer, in the term of six months next
following their filing. The entitie s referred to in this Title which keep their accounting
through manual or mechanized systems and those whose computing equipment cannot
process said devices in the terms so establ ished by the Ministry, shall furnish such
information on the forms approved for the purpose by the latter.

(3) Other information
The information on amounts withheld and person s from whom they where withheld on the
returns referred to in Section V of Article 118 and the final paragraph of Article 143 hereof
shall also be furnished on magnetic devices pr ocessed as indicated in the next preceding
paragraph.

Unions of workmen [2] Unions and organizations in which they are grouped are relieved from compliance of the
obligations provided in Sections I and II of this Article, except for those activities which if
performed by another person would be covere d by Article 16 of the Federal Tax Code.
Persons indicated in Article 95 thereof and not determining distributable remainder are
relieved from compliance of the obligations es tablished in Sections III and IV of this
Article.

Annual return[3] The persons referred to in Sections V through XIX of Article 95 hereof and the investment
companies referred to in this Title shall file an annual return on or before February 15 of
each year reporting to the tax authorities all revenues obtained and all disbursements made.

Dissolution of entities[4] When an entity included in this Title is disso lved, the obligations referred to in Section III
and IV of this Article shall be complied with in the term of three months subsequent
thereto.

Entities under no obligation[5] The civil associations referred to in Article 95 hereof which do not alienate assets, have no
employees and render services only to th eir associates shall be under no obligation
whatsoever.

Simplified accounting[6]

The associations referred to in the next preceding paragraph which have a maximum of five
employees and do not alienate assets shall be entitled to keep simplified accounting
registers.

Political parties[1] ARTICLE 102.- Legally acknowledg ed political parties and associations shall only be
obligated to withhold and pay over the tax and require documents co mplying with fiscal
requisites, when they make payments to third parties and are obliged so to proceed in terms
hereof.

Federal Government, States and Municipalities[2] The sole obligation of the Federal Government , the States, the Municipalities, and those
institutions which are obligated by law to de liver to the Federal Government the full
amount of their operating balances shall be that referred to in the first paragraph of this
Article.

Decentralized agencies[3] Decentralized agencies who do not pay tax pursu ant to Title II hereof shall only be under
the obligations referred to in this Article and those established in the two final paragraphs
of Article 95 hereof.

Debt-instrument investment companies[1] Article 103. The debt-instrument investment co mpanies referred to in the Investment
Companies Act shall not pay Income Tax, and their members or shareholders shall accrue
as taxable the interest revenue derive d in their favor by such companies.

Accrued interest[2] Interest revenue accrued as taxable as referred to in the next preceding paragraph shall be in
real terms for individuals and in nominal term s for entities, and shall be so accrued in the
fiscal year in which they are earned by the applicable company, in the amount thereof
applicable to each individual or entity in accordance with the amount invested.

Interest in favor of shareholders[3] Interest earned by shareholders of debt-instrument investment companies shall be the sum
of the profits on alienation of th e shares and the increase of value of the investments thereof
as of the last business day of the fiscal year , in real terms for individuals and in nominal
terms for entities. Both such items shall be determined as provided in Article 104 hereof.

Entities in investment companies[4] Entity members of such companies shall observe the provisions of Chapter III of Title II
hereof in respect of th eir investments therein.

Tax withheld[5] The investment companies referred to in the fi rst paragraph of this Article shall pay the tax
established in Article 58 hereof due by their members or shareholders, on or before the 17th
of each month next following that in which intere st is earned. Payers of interest to such
companies are relieved from the obligation to withhold established in said Article.

onthly tax[6] The monthly tax referred to in the next preceeding paragraph shall be the sum of the daily
taxes applicable to the taxable investment por tfolio of the investment company, computed
as follows: the tax on instruments the yield of which is paid in full upon maturity, as the
product of multiplication of the number of ta xed instruments of each nature by their
weighted acquisition cost multiplied by the rate established in Article 58 hereof, while that
of all other instruments referred to in Article 9 hereof shall be the product of multiplication
of the number of taxed instruments of each nature by the par value thereof, multiplied by
said rate.

Tax credit by entities[7] The tax paid by investment companies as provided in the next preceding paragraph may be
applied as credit to the provisional or final payments of memb ers or shareholders thereof
who are taxpayers under Title II or Title IV hereof and accrue the taxable interest from their
investments in said companies with their other taxable revenues for the fiscal year.

Computation of the tax credit[8] To determine the amount withheld which may be applied as credit by each member or
shareholder, debt-instrument investment companies shall divi de the tax due on their earned
interest which is taxed daily, by the number of shares in circulation of the end of each day.
The amount of the daily tax per share shall be mu ltiplied by the number of shares held as of
the end of each day. The amount of tax so applicable as credit shall be set forth on the
statement of account, record, ticket or noti ce of liquidation issued for the purpose.

Variable-yield investment companies[9] The variable-yield investment companies referred to in the Investment Companies Act shall
not pay Income Tax. Their members or shareh olders shall apply the respective regimes
applicable to the complements of interest, di vidends and profit on alienation of shares as
provided in this and other applicable Articles hereof.

Individual shareholders[10] Individuals who are members of the companies referred to in the next preceding paragraph
shall only accrue as taxable the real taxable interest earned in their favor as proceeding
from the debt instruments contained in said companies’ portfolios, in accordance with the
investment therein of each of its members.

Computation of intere st by individuals[11] The part corresponding to real interest of the daily revenue earned by shareholder
individuals shall be computed by multiplying th e revenue determined as provided in Article
104 hereof by the quotient of division of the tax interest accrued daily by the investment
company by its aggregate daily revenue dur ing the period of holding of the shares. A
valuation of the shares held in the company’s portfolio as of the date of alienation of a
share issued by it or as of the last business day of the fiscal year, as applicable, shall be
included in such aggregate revenue.

Computation of interest by entities[12]

Entity members or shareholders of variable-yield investment companies shall determine the
interest accrued in their favor from their investments therein by adding the profits obtained
from alienation of the shares and the increase in value of the investments in such companies
as of the last business day of the fiscal year , in nominal terms. The revenues of both types
shall be determined as provided in Article 104 hereof, and such entities shall observe the
provisions of Chapter III of Title II hereof as to their investments in such companies.

Tax withholding[13] Variable-yield investment companies shall wi thhold the tax on aggregate interest earned
established in Article 58 hereof and shall pa y it over on or before the 17th of each month
next following that on which is it is earned, a nd shall observe the provisions of the sixth
paragraph of this Article. The amount withhe ld from each shareholder shall be determined
as provided in the eighth paragraph of this Article and may be applied as credit to the
provisional or final payments of members or shareholders thereof who are taxpayers under
Title II or Title IV hereof and accrue the taxa ble interest from their investments in said
companies with their other taxable revenues for th e fiscal year. Payers of interest to said
companies shall be relieved from the obligati on to withhold referred to in Article 58 hereof.

Deduction of losses[14] Members or shareholders of the investment comp anies referred to in this Article and Article
104 hereof, who are individuals may deduct the lo ss, if any, determined pursuant to the fifth
paragraph of Article 159 hereof, in the terms of said provision.

Taxable interest and profit on sale of shares[1] Article 104. Members or shareholders of debt -instrument or variable-yield investment
companies who are individuals shall accrue as ta xable in the fiscal year the revenues from
the taxable instruments included in the portfolio s thereof, in accordance with Article 103
hereof. Such revenue shall be computed by th e operators, distributors or managers (as
applicable) of said companies. The following, in stead of the provisions of Article 24 hereof,
shall be applied to determine the part of the revenue applicable to profit on the sale of
shares issued by the company:

I. The number of shares alienated shall be multiplied by the difference between the sales
price and the weighted average acquisition cost thereof upon alienation, computed as
provided in this Article a nd updated as of said date.

II. The weighted average acquisition cost of the company’ shares shall be computed as
follows:

a) The initial weighted average cost thereof sh all be the unit price of the first purchase of
shares by the investor. If the investor holds shares acquired prior to 1 January 2003, the
price thereof registered on th e last business day of fiscal year 2002 shall be the initial
weighted average cost.

b) Upon the first purchase of the shares of said company s ubsequent to that giving rise to
the initial cost defined in th e next preceding subsection, the weighted average cost of the
shares of said investment company shall be recomputed as follows:

1. The number of shares included in the initial weighted average cost shall be multiplied by
said cost, and the product shall be added to that determined by multiplying the number of
shares acquired by the purchase price thereof.

2. The result of the next preceding number shall be divided by the total number of shares of
the investment company held by the sharehol der on the occasion of this computation.

c) Changes in such weighted average cost resulting from subsequent acquisitions shall be
determined by adding the aggregate value of the new purchase of shares to that of the pre-
existing portfolio and dividing the result by the total number of shares of the investment
company held by the shareholder on the occasion of this computation. It For said purpose,
the value of the pre-existing portfolio sh all be understood to be the product of
multiplication of the total number of shares th ereof held by the shareholder prior to the new
purchase, by the updated weighted average acquisition cost thereof.

d) When the last acquisition or shares has taken place in a previous fiscal year, the
weighted average acquisition cost for the above computation shall be the price current on
the last business day of the ne xt preceding fiscal year.

III. The updated weighted average acquisition cost shall be computed with the factor
referred to in the third paragr aph of Article 159 hereof, com puted for the period from the
date of registration of the pr ice applied for determination of the initial weighted average
cost through the date of the next purchase of shares of the same company. Said updating
shall be performed successively from the date la st mentioned to that of the next acquisition
of shares or that of alienation thereof.

Real increase of share value[2] The part of the revenue correspond ing to a real increase in the value of shares held and not
alienated as of the end of the fiscal year shall be determined by multiplying the total
number of shares held as such end by the di fference between the share price as of the last
business day of the fiscal year and the updated weighted average acquisition cost thereof,
computed pursuant to this Article.

Loss of investment[3] When an investor indivi dual determines that the sum of the real profit from alienation of his
shares of the company in the fiscal year and the real increase of value of his non-alienated
shares as of the last business day thereof is a negative amount, said amount shall be such
individual’s loss from his investment in said company.

Profit on alienation of shares[4] The real taxable interest earne d, the profit on alienation of shar es and the increase of the
real value of shares held as of the end of the fiscal year by a variable-yield investment
company shall be determined as provided for debt-instrument investment companies, but

only with regard to the proportion of its aggregate revenues during the period for which
shares were held by the taxpaying sharehol der or member, represented by its dividend
revenue and taxable interest during said period.

Rules for computation of interest[5] Through the Regulations hereof, the Ministry of Finance and Public Credit may issue rules
simplifying the determination of taxable intere st by members of variable-yield investment
companies, with basis on a formula whereby the aggregate revenues of such companies are
prorated to taxable interest earned from debt instruments and profits from Income tax-
exempt shares during the period of holding of its shares. It may also establish thereunder a
prorating mechanism to simplify the computa tion of taxable interest by debt-instrument
investment companies the portf olios of which also contain tax-exempt instruments.

Accrual of real interest as taxable[6] In addition to accruing as taxable the interest obtained by investment companies which is
taxable under this Article, individuals may el ect to accrue as taxable with their other
revenues in the fiscal year such real interest earned but not collected by said companies as
corresponds to them in accordance with their investment, and to apply the tax (including
that referred to in the penultimate paragraph of said Article) as credit in the terms of Article
103 hereof. Persons applying the option to wh ich this paragraph refers shall not be
obligated to accrue as taxabl e the profit on alienation of sh ares; upon exercise of said
option, it shall not be changed and shall be applied to all operations performed.

Evidence to clients[1] ARTICLE 105.- The debt-investment invest ment companies and the variable-yield
investment companies referred to in Artic lea 103 and 104 hereof, acting through their
operators, managers or distributors, as the case may require, shall furnish on or before 16
February of each year to their participan ts or shareholders and to all financial
intermediaries having custody and administration of such investments, records setting forth
the following information:

I. The amounts of nominal and of real interest accrued by the company in favor of each
shareholder during the fiscal year.

II. The amounts withheld which such participan t or shareholder is entitled to apply as
credit, in the terms of Article 103 hereof, or , as the case may warrant, the amount of loss
which said participant or share holder is entitled to deduct in the terms of Article 104 hereof.

Information to the Administration Service[2] The investment companies referred to in this Article shall report to the Tax Administration
Service, on or before 15 February of each year, through their operators, managers or
distributors (as applicable), th e data set forth in such evidences, and also the average
monthly balance invested therein in each month of the fiscal year by each person to whom
they were issued, and all other information es tablished in the form issued for said purpose
by said Service. Said companie s shall be jointly liable for any tax unpaid by their respective
members or shareholders when the information set forth in such evidences is incorrect or
incomplete.

(C)2004 Editorial Themis, S.A. de C.V.