Global Tax Strategy in Response of COVID-19 Environment

Miguel Juarez-Mendieta

Director - International Tax at Marriott International

Learning Objectives

As a result of COVID-19, there have been residence implications for individuals and corporations. In response, the government has developed incentives, credits, and new tax compliance. Teleworking, or working from home, is the new normal and with that it brings on new regulations and tax implications. Due to the pandemic, there is a measurement of tax risk and we must use tax analytics as well as US GAAP, IFRS, and new accounting principles to combat the issues brought on by COVID-19. In addition, the world has had to adapt regarding traveling as there is new corporate policies, and employee restrictions for traveling and updates on the code of conduct. However, there are new tax opportunities and tax strategy because of COVID-19 and there is a global tax strategy for multinational corporations in response to the pandemic.

Key Takeaways:

  • An overview of tax implications generated by Teleworking (home office work environment) as such tax residence, travel restrictions, incentives, and new regulations

  • Recognizing the importance to measure tax risk derived by COVID-19

  • Tax strategies that can be implemented by multinational corporations in the US, Latin America, and Europe

"Implement a strategy for tax purposes while considering alternative incentives issued by the government. "

Miguel Juarez-Mendieta

Director - International Tax at Marriott International


Good morning, everyone. I hope this video finds you as well. So please stay safe, we’re still facing a lot of situation a problem because it could be a situation where I hope we can resolve the situation soon. My best wishes for you and your family. At this moment, we have to continue following distortion of the governments. And as they say, My name is Miguel Juarez Mendieta. I am director of international tax on Marriott Hotels. And today I will speak with you about the covert taxes, right the response of the COVID-19 environment, a really good topic. Let me introduce myself, I have been working in all the tax accounting for more than 20 years, helping multinationals or making some kind of operations like marriage acquisitions, spin offs, and these kind of things, and advice for the tax consequences of these operations. I’m delighted for being here. Speaking with you. And for me, it’s very important to race over to you these a specific topic that is attached strategy that we have to cover as professionals, when we are working in a multinational or even for individual purposes, when we want to just take advantage of the tax benefits are probably the government issue to the resident in the country. So at the end of these conversation, I will like to have in these three main objectives over to June. So the first is going to give you a general picture, here are a picture of a tax implication that have been generated because of the coffee, and specifically to teleworking. So the second goal that I have for this presentation is about the recognizing portion of measure the tax rates, the tax risk, and everything that is related to the carbonating on how we can implement a good strategy for having audit risk control. And finally, I will have some examples for the strategies that can help us to just to face the situation that we are we are having in our Corporation as as individuals, just to try to take advantage of the situation that we have, because of the pandemic. So let’s get started. So the first point, as I pointed out, is a general election. So

I’m pretty sure when the situation arrived, whereas certain areas, we’re still and the first question that probably you and your family may have is about if you want to stay or should, you should go to other place, right. So maybe in this difficult time, you want to be pretty close to your family, to your friends. And sometimes it’s not in the same essay have to be to move to other state or even in other countries. So that is the first implication that we have with the COVID-19. So should we stay or should I go. So when we face the situation, the majority of us were just to be in contact with our families, and we decide to stay or go is put in as an example. My family situation, so I am from Mexico, and the very beginning I wanted to return to Mexico with all my family. But my wife and I, we decided to stay here in Florida, where is our, our home, or probably the other opportunity that we have is to move to North Virginia where we have other friends and we used to live there, but moving from one place to another that implicates tax residents and we have to be careful about that. So if you say is okay, but if you move, you’re definitely have to communicate this to your employee, because that probably will have resident implication. And what is that, of course, every single state and every single country has their own understanding their own basis about the resident, but more or less the general rule about a resident is the place where you are doing is the place where you are living. So that is considered a resident for tax purposes. And in some cases as well. So it’s considered when you stay physically, I mean, there are physically more than 183 days that means that you have resident there and that is an implication because imagine, as I pointed out, I am working for a multinational, located in plantation Florida. So, normally here, we don’t pay state taxes. So we have certain levels of payroll and other kind of tax, right. But if I move to another state, probably not be as Junior, that means that I will have to change my resident could be or could not, we have to analyze this, if I moved to California to New York to other places that have an implication. And not only that, also, if you move to all other places around the world, as I pointed out, probably if I would decide to move to Mexico, so I want to be aware, if I can be a considered as a double resident, person or not. And the implication is for the companies as well, because as I pointed out here, working for corporations, so when you are making business in all in one place, that means that you have to pay taxes there. So probably my company doesn’t want to, to be involved or having some kind of resident in other country, right. So there is a reason that you have to be aware, speak with your your employer, and then know that you were traveling, because that can save money and situation about the restaurant. Because as I pointed out, the rules change, and sometimes a will have implication for our Corporation as well.

Let’s move to the second point that as a general picture, so say you’re working from office, right, so working at home, and the regulation and tax implication that have been in issues, since they started with a pandemic. I remember three or four years ago, some of coworker told me, you know, why Miguel, you should be much further working at home, because you have the advantage that you have to don’t have to commute, you don’t have to, I mean, to spend a lot of time for being in the office, I mean, Bing, or probably also, you can manage your time pretty well. Because when you are in the office, while so. So sometimes you cannot manage the activities you have. And also I would like to spend more time with your family and just to be in contact with the environment I have at home, they said that so but nowadays that with this new reality that is the home office of teleworking, either for my co workers, I was saying the positive so well. So now with this situation, I am working more, sometimes I have to work 11:12am 2am something like that, I have to work Saturdays, Sundays, I really don’t have an escape for work. Some of them say well, so you know why it’s difficult because I cannot concentrate here at home, I love noise if people are here and so really, I cannot advance with a with a wall was that I have for this month, or there says well, so is expensive, because I have a lot of expense now that I didn’t have it again, today working has some kind of pros and cons, but we have to be aware of these because this is our new reality. And guess what, this is never going to change. So, we will have these for at least older years. So, we have to be try to adapt to this new reality and try to get the advantages that we can have just working at home. So, definitely the recommendation of the government is to stay at home because that decrease the level of the of the people that can be in contact with we will call it right. So and that is very important just to follow up. And because of that the government has issued some regulations that can help to the employers and employees about this new relation. I can imagine some question from the audience as well. So, I used to work in that office. So now I am not working there anymore. I am working on how should I sign a new contract or should I be okay with this contract that I have? Should I put any in writing all the goals that I have with my employer about this new reality? So that is a question the problem we have. So as I mentioned before, probably you will have to upgrade your Wi Fi. Probably you have to increase the amount that you are paying for electricity. So you have to pay for some kind of supplies for office. You are asking, Can I be reimbursed for these kind of expenses that I didn’t have before? I mean are business related Should I Consider that I should be reimbursed for these kinds of expenses are probably and more important thing is scheduled a time. Because I pointed out, I know that it’s important for a worker, we don’t want to still work in Saturdays and Sundays, right? So this is very important just to set the rules for the project that you’re working on some government already work on that. So in some countries, there are some regulations about the schedule of time for making these some inset incentive for making our tax a benefits about the working for the NDP, it was also a government issue, some kind of regulation, just to consider as a deduction, or probably reimburse these expenses of the Wi Fi, of the suppliers of suppliers. And this kind of directed electricity that, as I pointed out, probably we are expanding because of the COVID.

Within the size of the corporation, as well, so so the government is trying just to help just to regulate about these, in the in the United States, we have some kind of regulations as well, as I pointed out government registration is regulation to have the parking right. So the reverse happens to be partially or fully as a pain of the of the country’s countryside, France, Mexico, Canada, are already issued accusation about these. And in the United States, the Department of Labor and Internal Revenue Service, the IRS have similar a regulation body to the federal Fair Labor Standards service contract, remember some of corporate visits, etc. So, so basically, you have to be on top of this regulation, and understand if you can qualify for the last a kind of a benefits, if you are making it a working, there are some words like the people have to be physically in the office. So unfortunately, they have to do it. But the good news for us is that sooner or later, we will have this revelation that will help us to have this relationship between employers and employees. As I pointed out, this is something important that we have to be on top, because he’s the new reality, and we will have these in the near future. Alright, so other aspects that we have to consider, because of the condom pandemic is a corporate policy. So restriction for travel, as you know, with an eye straining at the very beginning of this conversation is that we want to because with friends and family, because he’s a great place just for feeling good, right. But as of today, the recommendation from the government is don’t travel, I mean, isn’t necessarily You have to do it, but please don’t do it. So, as a company, we have the necessity just to change the corporate policy, find yours to make a restriction to the employees, because that will help just to decrease the level of the other people that that have a considered a positive of the COVID. So, we want to help to the government about that. So, you will see that in the in the condos, policies of the company will include these kind of policies for restriction for crop. The other point that is important too, to mention for the general picture is about the government incentive credits and the and the implication that they have. So certainly the government start issuing some incentive credits. In United States we have these famous cares act where the individual had received some money, the Small Business received some assistance as well. But a unfortunately is not good enough, or we want to take care of that we want to be on top to understand that we have something that they can apply and just to take advantage of these kinds of incentives. The governments around the world are doing that. Because a very important, the most important is is the health the people so so we really are are happy because now we have a scene for these kind of videos difficult just to to get into all the people but but we are working on that. So I’m saying as a human being, but the economic part is important because I know that other people are losing a job jobs and a money. Sometimes a job you are not able even to pay the house. So taking in consideration that the government Has issue some kind of incentives credit that can help to just to deal with facing these kind of problems is the facts of this case is a bunch of equalization, but my recommendation is just to take a look on this kind of incentive, generally speaking. So, for tax purposes, what happened is that Joe as a company will be able to reduce the level of pay in taxes, because you can choose the taxes with the famous carry back and carry forward. So I will explain these in detail later on. Also, you will be able to receive some kind of incentive a money, see if you are a small business, you will receive something like that. All, all things, all the thing that is important is the extension of the day things for the

filing tax return. And this is important as well, because a release a dangers of the penalties or interest, you have to pay if you are with the filing of the terrorism, or these kind of incentive credits have been issued by the government, including United States, of course, not in America, Europe. Again, all of these is because we have to be in the same page. So it’s something that is important, because we know that we want and that we can resolve this issue. And for tax purposes, the government is a way that helps contribute with that, I finished my first part of the conversation. So just try to make some kind of summary is very important to to understand the implication that the COVID is is generating because of of the relationship between the corporation and dividuals. So we need to be on top, we have to realize that we need to analyze case by case about the situation that we have as an individual of or the corporation that we are working for. All right, thank you for continuing with me. So now I will talk about the second point of this conversation that is this the risk, really for the COVID-19 of course, regarding the tax. Alright, so in this second point, we will talk about the tax rates that have been delivered by the community, the first thing that we have to do as a professional is for having a list of audit risk related to this community, our very least that you can do it in Excel even in Excel is important just to try to put it all together all the all the risks that you identify with, regarding the COVID-19, I don’t know if the more important is cash, cash raise a commitment with a provider’s with clients. Private property you have a, a to commit with some covenants with the bank. So this kind of situation, you have to make a list of all the situations that probably are on risk, because of the pandemic situation, of course, as well, they, with employees with a with it with a cause related with the insurance and health and these kind of things. And then without, you have to rephrase and restructure your the way that you measure the risk, I mean, you have to make a deeper analysis about the the, the way that you are measuring the risk, so the management of the risk is very, very important. So the first point that you’re gonna do is gonna appreciate this streamline. So that means that if you used to have a process in place you have to reshape is this, this is streamline, and enhance optimization, because as we as we pointed out, we are going to be online, we will be working remotely. So it’s very important that all the process of the management of the risks have to be a without the monetization. So use that if you don’t have I know that it’s difficult just to invest in the same kind of toll that at this moment, but if you don’t have to, you have to ask or you have to take in cars, because they actually have in the out of out of monetization of the processes including their risk. The second point that is important is increasing the monitoring of the process. So we talk about that we have to put in writing all the all the new rules for making business from the employees and from the employer. So in this case, is difficult for the employer just to be on top of the employees right so we don’t want to act as a police. So, but it certainly we have to understand that at the end. A company is is a May in order to have in the shareholders making business making some kind of profits. So, that is a goal for making a corporation. So, I search, we have to be able to monitoring the processes and just to make the results. So, in this measurement of the risk, we have to step up on the on the monitoring of the process. And of course, as well if we can include the optimization much further

after that, we will have the reporting term they even this is another topic that probably we can talk the hitter in other conversation, but automatisation now, nowadays is important. So, we used to do a lot of things a manual for accountant, like me, I remember the old days, when you will spend a lot of time just to try to to make the balance sheet the p&l. So, now with a click by this, you can you can get all the information. So, take advantage of these a kind of a products that will probably have an actually cannot be some expensive some kind of the basic tools that we have can happen just for having a wrapper and try to make everything in automatic I mean optimization in reporting is important as well. And after making this process, very important needs to be focused on the on the key risk always always for corporations is important to understand what is the current business what is what is exactly what what what we want to take care of, because again, we know that we are facing as a province, we know that is difficult service time just to get that resolved. So can you imagine industry like the one that I am, where a Jew drop off all the all the numbers and you don’t have people probably so. So really you are making a lot of a big decision for us to try to keep keep ahead with operation. So but you have to understand what is a key risk that you will have the core reasons that you have an M could be one could be three cannot be 11. Right? So very important to identify on that at this moment. Because a the resources I buy are, we don’t have the resources. So we really have to be focused on the most important. And finally, we this cycle is a compliance. So we are in a difficult situation. But that doesn’t mean that you don’t have to pay attention. The compliance, the compliance is important is still in the key in there there is compliance is important for procedures just to is approved that you made a work. So for the government, in this case for taxes. It’s no question about we have to continue making the annual tax return of course we want to use to try to reduce our own tax payments probably. But we want to be on top we want to continue with the compliance because this is very important for our business don’t don’t don’t pay attention in I will say in in in the details a purple in the big picture. I will say that that I you have to continue filing the tax returns you have to be in compliance a on time with a with their dance. Of course, I understand that from you want to just to say don’t pay because cash is very important at this moment. But maybe that is not the answer. You have to continue with a complaint you have to pay your debt you have to I’m talking about with the tax writer so you really need to continue having this this process taking place and continue to be a in good shape with the tax authorities. So again, this coffee aside conclusion of the second part of the conversation, we can see that probably because of the pandemic some of a the decision made by the leadership of the company there is that Okay, stop paying taxes are probably tied to delay the payment of taxes. I don’t agree with that

kind of idea. So So why do you have to do is really just to understand what are your possibilities for reducing taxes take advantage of the crates, but we need to consider that it’s very important to continue with the compliance. So there is a big risk if you don’t a May Day a properly compliance on filing the tax return. So please be on top of that. And of course To a VM time with all the regulations, and not only federal states and nationally, you have to continue with all the deadlines and filing on time. So, as an accountant, as a professional, we have to be on top of the new regulations. As I mentioned before, we have new revelation for tax purposes, but for accounting purposes, we will have a lot of new revelation that we have to be on top and we have to be clear about this revelation. So, just God I forays a new accounting principle, our new issue because of the COVID-19. So, our auditor normally will include a paragraph or disclosure on the on the opinion of the financial statements about the COVID-19. So, we have to take care about situation like going concern as a new principal valuations a fair value, and this kind of thing that had to be important for our companies and also for those individuals have a business by themselves. Again, so, because we are talking about risk, we are talking about a new requirements regulations and new incentives, even if those incentives are really good. So, we have to include these in the footnotes of the financial statements and that is very important that you just to take a look right. So, so, globally, you will have the situation with a with the auditors with accounting teams used to having new discussion to have to incur in in the in the opinion of their financial statements in the footnotes, and some of them related to taxes as well as I will considerably in the following topic. So, if you are taking big advantage of the taxes you have to put on different answer these things and even for accounting purposes and things like a reserves, so maybe they should be a valuation other ones so, you have to make a refacing impairment a measurements of certain assets, they’ll probably have to be adapted for for these new reality in a dramatic a work or environment in mind, you have in a big office a VAT is an asset for the company and now you are not using or if you recall, we are renting data and that and you have to consider different So, every single operation that we are making and decisions and everything has to be protected areas have to be included in the financial statements. And it’s important that you consider these and I put in as part of the tax a risk because it’s very important that you equal all together in the information that you share with a stakeholders say you are a public entity a with all the shareholders a outside of the organization, if you are a private company with it with with a shareholders of the company with a with the banks and and so on, very important you have to be on top of that strategy is fundamental for the business any kind of business. So, strategy is a way that you will tackle when you will face a situation and a big problem like we have at this moment with a copy right with a pandemic situation. So, for tax purposes, we have to have an extraordinary you cannot be there as an individual or corporation without any idea any kind of a plan. So, you have to make a plan your own plan accordingly. There still costs circumstance you have the situation that you have, and the possible benefits that you will have with the government with a with a new laws that are making someone available for you. So you have to generate uptime is very important as an administrative process, you have to have a plan that is essential for any kind of situation, in this case for taxes, you

have to have a plan, right. So, that is a strategy that we are going to have over here. And these are some ideas. The first, the first thing that we have to understand is that every time that you have a problem, you can see that there is an opportunity. And as I pointed out you have to have an a strategy in order to just to face the situation. And just to pass it on. Right so just to face it and just to resolve so a difficult because I know that this is a situation very very hard for the corporation and individuals but I’m pretty sure that we we can face it and we can resolve it so and the first strategy that I have a an I know that the corporation multinationals are thinking about cash management. Cash is important in this kind of things when you have a problem. Unfortunately, this pandemic situation in when is when When there is kind of difficult situation economic, political and kind of a situation a that where you, you are not able to be free for making business the management of the cash is important cash is a key at this moment. So, you have to be over four have a cache management pretty well. And again, so, we have to understand what is where our our place right. So, you got an individual and excel with a cash flow all the incomes and expenses is good enough to understand what is the necessity necessity of cash that we have, he required a corporation you will have some kind of a systems that and and models that will give you the the in and out of the cash. But very important is that you manage the cash. for tax purposes, there are some kind of proposals that can help just to leave companies to get stash. For instance, repatriation of money. So some of them multinational are located in a connotation around the world, their subsidiaries branches, and they can repatriate this money back to the United States, for instance. And in some countries, like Brazil is a good example, don’t have any kind of a withholding taxes on dividends. So probably you can take this advantage and say, Okay, listen, so why don’t we just to repatriate cash to United States, this is one way or the other way is just to say that. So, maybe in tech companies, or will you have instead located in save time in countries, you can pay the debts that you have between one on another. Again, so if you if you are located, for instance, for the hotels and the the industry that I am working now, if you have the ability to concentrate cash, and you don’t know how to use it, so why not you you invest and you make every modulation of the hotel, in this case, it’s going to be some kind of new asset for the company. So you have to see how collect the cash and how to manage to distribute in in A, B or C, but for doing that you have to have a model of cash, cash is a key at this moment. Or the other way that you can get cash is with a global restructuring of the company analyzing a what should be the correct or the effective tax rate. So what I’m saying that, okay, so normally, as a corporation, multinational you have holding company, for instance, in Switzerland, or probably Luxembourg, or some kinds of seen in the islands. So with these eight shelter companies, and after that you have the operation companies, you have the the way the companies are really two employees. So you have the oldest structure in a way that you can be efficient with attacks, error rates and and how you are managing, you’re sure you’re global, a change of the of the company, you have to revise that because probably you have to change it. And that is a good opportunity just to because Venus in some places are opening other ones so that you will generate cash. So and again, after that you can revert to a to United States. So you have to be on top of that just to double check with a with a structure that you have, and probably is whereby the structure can be changed and that we generate cash, that it can be used for the for the companies.

Another thing is a management of withholding tax grades in 2018. So in United States, there was a new, we say build new regulation for taxes that probably we can take advantage of that. So so some places where we can, we can manage the credit for withholding tax, that means that Okay, so if I pay as a multinational, in other country in order equalization taxes, that saying withhold taxes, so maybe that can be used for the local purposes, in this case, the United States to let us pay taxes, because we will be able to offset or decrease the volume of the withholding taxes. I mean, this whole idea, so of course, you need a plan. But the point here is that you have the ability to just to manage it, we call in tax credits. It’s not that easy. You have to have an idea and it’s not 100% but a at least you can recover some kind of the payments may have indirect taxes, a VAT refund of the vat. So in places like Latin America, we have implemented the the VAT Europe as well. So, sometimes when the VAT the input is is a more than the output, you have five whatever the VAT that you can recover, sometimes they efficient way to do that is just to use for not paying future liabilities, but in some cases and in the majority of the cases, you can touch base with it with the tax authorities local reference of the of the countries and say, you know, I want to get a refund of these indirect tax and that is funny. So, that means that probably you have some opportunities are there that you have companies that you can take a look in the in the balance sheet and probably you have overpayment of taxes, a tax payments, or are these a VAT favorable that can be recovered as cash, I mean, tax refund that you can claim and you can fight with the tax authorities, thus, he saw the way that you can get money, again, this is most important is the number one cash management, you have to understand how you can control the amount the expenses, reduce the general expenses and costs that you have in the in the business, but certainly I am, I mean, it’s no magic. So, in the PnL you have to be big a part of the p&l is income and costs or expenses. So, I am saying that a way that you can increase the income or I will say, a generate cash, because the other part is kind of difficult because expenses at the moment, of course, we are paying rent this a lease of the office we are paying less for unfortunately, because because we have to adjust to decrease the level of employees but is difficult and we will face more permanent. So my idea of Cashman have to be focused on the increase in the ability to generate cash a big way with this a tax strategy is that I explain what to

do number two,

the utilization of taxes. So, the majority of the countries including their rules, not not because of the COVID is because Is there a regular way that we we have these environmental taxes is that when you generate no sales tax losses, so you can be able to recover or pay this tax in the future, that is considered the carry forward for five years, 10 years in advance of contract. But that if you have an opportunity for having an idea on Pay status is is a good way and you’re not making any kind of money, it’s just to further window, but here is something very interesting the carry back the carry bag is the way that you can consider some government like


like us, you can make recovery back and what is that is that you can just to let me put in India amend or make an amendment of the tax return the prior tax returns and just to claim their return of tax refund, because because now you are generating tax sources that can do you can use for us period what I mentioned idea right so because in my in here, as I pointed out, we have a big change in United States in 2018 where companies used to pay a rate of 35% and now we are paying 21% of corporate rate. What does it mean is that the US companies can use the assessing quarter before during the pandemic to offset up to five years of us profit companies can get refund of taxes that they pay and 35% and now the rate is 21% This is a final carry carry back provision. So, again, you can take advantage of this provision and and probably you will have some money extra for the company, because of this rule, carry back roll on internationally, many countries are either permitting or expanding the provision they can relax or a company can I mean don’t have limit of the tax losses, some some cases like Brazil or maybe Honduras, a you have a limitation of use of taxes as of today. They made of operating profit that you have so I mean, in other words, you cannot use the 100% of the taxes that you have. But because of the COVID some of them has really some kind of vitality just you can choose more taxes. So in this list a component is used the tax versus the taxes looks bad, right but in these this situation, probably have good So, that’s those this alternation is something that you can use as a strategy for for just to, to get in getting a incentive for tax purposes. Number three IP valuation, the IP is the intellectual or intangible property, right. So, very important for tax purposes is a, I will say that, this is a most of the important things in taxes nowadays, in that the substance are pretty to be topics. So, normally the multinational they have an a structure where you locate the IP rights in certain places like United States, like Luxembourg. So that means that those corporation or those companies located in those places, has the right for issue some kind of brands, like the brands, the name of the company, and send invoices to how we say, a business in all in all part of the world, a, like a royalties franchise fees, or maybe a kind of fees. But for doing that, and to be able to do that you have to have the IP rights. That could be an advances, so so maybe you have to just again, just to try to understand what is the situation of your company, maybe you can change it, and you can make an infrastructure of the company and move the IP one place to another. So maybe I remembered probably 20 years ago, something was expensive for having these IPS in United States are probably because the new regulation and the FDI a foreign derived intangible income, a 404 a, for us purposes, the rate for paying taxes to move the IP is about 15 point 12%. So probably it’s a good idea to change the IP and put in everything in United States, now we’ll save some money because that that I mean, couldn’t be not expensive, and having all the rights for for getting captured all the all the cash in United States. So together convey on the structure that you have in your companies, of course, this is a plan because he’s not very easy you have to move moving IP rights from one place to another has a lot of implication but that could be any strategy for having some kind of facing day they call it at this moment and you can take opportunity, having some savings and have a restructure of your company right. So, merchant of decisions, that is the other one to want to be honest, they a lot of a company’s own the majority of the companies, we have problems of cash,

because of the pandemic, those companies are really to the to the to the hospitality industry to the to the transportation, these companies are facing a lot of problems, well, there are other ones, like the communication company, like the retail companies are probably they continue with a good levels of of having a, a having a good net profits and everything. So, for them in this pandemic a could be a good opportunity for having some kind of merge acquisition. So, so that is good, could be a good strategy. And even for those that we are struggling about this, so, about the situation, so probably probably am saying that merge company can help because if you you have to analyze pretty close to the realization body mind that you have two companies in Mexico, one with taxes and other one without taxes, if you made the merge, probably the one that has taxes this can help just to ask us for for for for us the tax rate of and the amount of paying taxes. So these kind of things can help us answer the the merge are important as well. And finally, the Swati that you can consider is transfer pricing. So transfer pricing is very important topic. So with the IP, I know they kind of have a accounting and taxes procedures. So you have to revise your your, your a structure change and all the entities that you have. You have to be in touch with the tax compliance without surprising ties. Now they follow in the OECD. But probably this is a good opportunity are really good opportunities to move. The place where you want to generate and devalue. I’m saying so transfer pricing is about a where Inc. The correct in the correct place where if you are generating a add value or value of a of the company, so maybe as part of the structure you can, you can change and say listen to maybe we can put a more emphasis of the asset a risk and function in one country that probably has a beneficial rate for tax purposes. And moving on from someone that other places that probably we don’t have a advantage for tax purposes, at this moment of a we can take a look again of the of the structure that we have, probably make a strategy for changing the how we are located the add value in each our company for pricing. Alright, so this is about cooperation. But a, of course, is not a case at this moment. But I wanted to say very quickly about the individual. So for individuals, you have to take care of our take a look on the local regulation, but a some good ideas a could be for for people to pay your front a plan for contribution, like a 529. So if you have kids, you have kids, and you want to take advantage of the and you have a good level of cash support, you can invest in their 529 brands, that Callaway with a video showcasing the features that can help you for tax purposes, invest a with our health savings accounts each has a so there’s other things that you can do, and refinance your mortgage. That is another thing that you can do for individuals. And, again, you have other other things that you can do, but is not part of this conversation, but be on top as well of the incentives that you’re probably can have for individual purposes. And there are a lot of them, of course, depends of the situation. So but very important that you can just to see how you can help yourself. Alright, so without I’m gonna finish draw, I want to set up just to having the takers take takeaways of this conversation, this summary of this is okay. So, again, the cause of this conversation, one three, and we will summarize that this moment, again. So a understand that we have tax implication, because of the new regulation of the coffee is specifically a work, please be on top of that number to be work in the risk management, please identify opportunities for being improved, so so very important that you can work on the management of your risk.

And that considering tax and accounting purposes, and finally, implement a strategy, a strategy for tax purposes, considering alternative incentives, issued by the government, all these kinds of things can help you to have a better idea of how you can face it. And again, I know that it’s a difficult time, I know that we are facing a lot of problems we’ll come to continue to work in is going to be with us forever, however, at least for the following years. So be patient. So some of the situation and five figures to be focused on the strategies that can be used to to be on behalf on getting all the advantages of of the initiative of government that have been issued for the situation. Or design. Please stay safe. I know we are going to win control this pandemic. So thank you for the attention. Thank you for the for the tunity I hope you’re having a fantastic day and talk to you soon. These was Miguel, this is Miguel. Talk to you soon.

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