Tax reassessment decision by the Mexican tax authorities concerning the transfer of an overseas power-generation business to JERA

「Because the contents of the notice are unreasonable and contrary to the Japan-Mexico tax treaty and Mexican tax law, the company filed an administrative appeal with the authorities on 10 February 2023. In addition, consultations between the tax authorities of the two countries under the Japan-Mexico tax treaty are under way.」

「With respect to the transaction under which the overseas power generation and energy infrastructure business was transferred to JERA through a company split effective 1 July 2016, the company received a reassessment decision notice from the Mexican tax authorities on 17 December 2022 (Japan time), ordering payment of 9,521 million Mexican pesos (approximately ¥75.9 billion). Because the notice is unreasonable and contrary to the Japan-Mexico tax treaty and Mexican tax law, the company is preparing to file an objection challenging the reassessment decision with the authorities.」