DECREE No-6,000, DE December 26, 2006

Promulga the Convention between the Governments of the Federative Republic of Brazil and the United States Mexicans Intended to Avoid Double Taxation and Prevent Fiscal Evasion in Relation to Income Taxes, celebrated in Mexico City, on September 25, 2003.

THE PRESIDENT OF THE REPUBLIC, in the use of the attribution conferring you the art. 84, inciso IV, of the Constitution, and

Considering that the Governments of the Federative Republic of Brazil and the United Mexican States celebrated, in Mexico City, on September 25, 2003, a Convention Destination to Avoid Double Taxation and Prevenir the Fiscal Evasion in Relation to Income Tax ;

Considering that the National Congress has approved this Convention through Legislative Decree no 58, of April 17, 2006 ;

Whereas the Convention entered into international vigor on November 30, 2006, pursuant to the paragraph 1º of its Article 29 ;

D E C R E T A:

Art. 1st The Convention between the Governments of the Federative Republic of Brazil and the United States Mexicans Intended to Avoid Double Taxation and Prevenir Fiscal Epoon in Relation to Income Taxes, celebrated in Mexico City, on September 25, 2003, apensa by copy to present Decree, will be executed and fulfilled so entirely as it contains.

Art. 2nd They are subject to approval by the National Congress any acts that may result in revision of the said Convention, as well as any further adjustments that, in the terms of art. 49, inciso I, of the Constitution, carries charges or engraved commitments to the national heritage.

Art. 3rd This Decree goes into effect on the date of its publication.

Brasilia, December 26, 2006 ; 185th of the Independence and 118 o of the Republic.

LUIZ INACIO LULA DA SILVA

Celso Luiz Nunes Amorim

CONVENTION AMONG THE GOVERNMENTS OF THE REPUBLIC

FEDERATIVE OF BRAZIL AND THE UNITED STATES

MEXICANS INTENDED TO AVOID THE DUO

TAXATION AND PREVENTION OF TAX AVOIDANCE

IN RELATION TO TAXES ON INCOME

The Government of the Federative Republic of Brazil

and

The Government of the United Mexican States,

(henceforth assigned?Contracting States?)

Wish to conclude a Convention designed to prevent double taxation and prevent tax evasion in tax on income,

Woke the following:

ARTICLE 1

Visit People

The present Convention shall apply to persons residing in one or both of the Contracting States.

ARTICLE 2

Targeted Taxes

1.A this Convention applies to taxes on income chargeable by each of the States Contractors, whatever the system of their exaction.

2.Os taxes to which the Convention applies are:

a) in Mexico:

-the tax on income

(henceforth called the "Mexican tax") ;

b) in the Federative Republic of Brazil:

-the federal tax on income

(henceforth named "Brazilian tax").

3.A this Convention shall also apply to taxes of an identical or substantially analogous which are introduced after the date of signature of the same, be in addition to those mentioned above, be it in their replacement. The competent authorities of the Contracting States shall communicate the important modifications which have occurred in their respective tax laws.

ARTICLE 3

General Definitions

1.Nesta Convention, unless of the context if it infused a different interpretation:

a) the term?Mexico? means the United Mexican United States ; employed in the geographical sense, signifies the territory of the United Mexican States, comprising the integral parts of the Federation, the islands, including the reefs and islets in the adjacent seas ; the islands of Guadalupe and de Revillagigedo, the continental shelf and the marine background and submarine subsoils of the islands, islets and reefs ; the waters of the territorial seas and the inland sea seas and beyond them, the areas on which, in accordance with with international law, Mexico can exercise sovereign rights of exploitation and exploitation of the natural resources of the marine fund, subsoil and underlying waters, and the airspace situated over the national territory, in the extension and under conditions established by international law.

b) the term "Brazil" designates the territory of the Federative Republic of Brazil, this is the firm land continental and insular and respective airspace, as well as the territorial sea and the berth and subsoil of that sea, within which, in accordance with International Law and with Brazilian laws, Brazil can exercise its sovereign rights ;

c) the expressions "a Contracting State" and "the other Contracting State" mean, according to the context, Mexico or Brazil ;

d) the term "person" comprises of a physical person, a society and any other group of people ;

e) the term "society" means any legal person or any entity deemed to be such for tax purposes ;

f) the expressions "company of a Contracting State" and "company of the other Contracting State" mean, respectively, a company operated by a resident of a Contracting State and an enterprise operated by a resident of the other Contracting State ;

g) the expression "international traffic" means any transport carried out by a ship or a aircraft operated by a company whose effective driving seat is located in a Contracting State, except when the ship or aircraft is operated exclusively between places of the other Contracting State ;

h) the term "nationals" means:

i) all physical persons possessing the nationality of a Contracting State ;

ii) all legal persons, societies of persons or associations whose character of?national? derive from the laws in force in a Contracting State ;

i) the expression "competent authority" means:

i) in Mexico, the Registration of Finance and Public Credit ;

ii) in Brazil, the Minister of Finance, the Secretary of the Federal Revenue Office or its representatives authorized.

2.Para the application of this Convention at any time by a Contracting State, any undefined expression in it shall have, unless of its context, if it inflictions a different interpretation, the meaning which at that time attached to it the legislation of that Contracting State relating to the taxes to which this Convention applies. Any term under the applicable legislation of that Contracting State shall prevail over the intended meaning for said term under other laws of that Contracting State.

ARTICLE 4

Residence or Tax Domicile

1.Para the purposes of this Convention, the expression "resident of a Contracting State" means all person who, by virtue of the legislation of that State, therein is subject to taxation, on the grounds of his domicile, residence, seat of direction, place of constitution or any other criterion of an analogous nature.

2.Quando, by virtue of the provisions of paragraph 1, a physical person is resident of both Contracting States, your situation will be determined as follows:

a) this person shall be considered resident of the State in which he / she has a permanent dwelling ; if she disposes of a permanent dwelling in both states, will be considered a state resident with which her personal and economic links are narrowing (center of vital interests) ;

b) if the State in which such person has the center of their vital interests cannot be determined, or if she does not have a permanent dwelling in any of the States, it will be considered a resident of the State in which to remain habitually ;

c) if you remain habitually in both States or if you do not remain habitually in any of them, will be considered a resident of the State of which it is national ;

d) if it is not national of one of the States or if, in accordance with the legislation of one of the States Contractors, for national of both States, the competent authorities of the Contracting States shall resolve the issue of common agreement.

3.Quando, by virtue of the provisions of paragraph 1, a person, who is not a physical person or natural, shall be resident of both Contracting States, the competent authorities of the Contracting States shall do their best to resolve the case. In the absence of a mutual agreement, such a person shall not be entitled to any of the tax benefits or exemptions contemplated by this Convention, except in respect of Article 26.

ARTICLE 5

Permanent Establishment

1.Para the purposes of this Convention, the expression "permanent establishment" designates a fixed business installation upon which a company exercises all or part of its activity.

2.A expression "permanent establishment" comprises especially:

a) a seat of direction ;

b) a filial ;

c) an office ;

d) a factory ;

e) a workshop ;

f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources.

3.Uma works, a construction, installation or assembly project, or a supervision activity to these related constitute a permanent establishment only when such a work, project or activity has a duration of more than six months.

4.Não notwithstanding the preceding provisions of this Article, the expression shall be deemed to be "permanent establishment" does not cover:

a) the use of facilities solely for the purpose of storage, exhibition or delivery of goods or goods belonging to the company ;

b) the maintenance of a stock of goods or goods belonging to the Company solely for the purposes of storage, exposure or delivery ;

c) the maintenance of a stock of goods or goods belonging to the company solely for the purposes of transformation by another company ;

d) the maintenance of a fixed business installation solely for the purpose of buying goods or goods or obtain information for the company ;

e) the maintenance of a fixed business installation solely for the purpose of developing, for the company, any other activity of preparation or auxiliary character ;

f) the maintenance of a fixed business installation solely for the purposes of the combined exercise of the activities mentioned in the incisos a) to e), on condition that the set of activities of the fixed business installation that results from this combination conserve their auxiliary or preparatory character.

5.Não notwithstanding the provisions of paragraphs 1 and 2, when a person-who is not an agent independent to which paragraph 7 of this Article-atue is applied on account of a company and has and usually exercises in a Contracting State powers to conclude contracts on behalf of the Company, it shall be considered that such a company has a permanent establishment in that State for any activity that this person develops for the company, unless the activities of that person are limited to those mentioned in paragraph 4, which, if exercised through an intermediary fixed business installation, would not allow for consideration of such fixed installation as a permanent establishment under the said paragraph.

6.Não Notwithstanding the earlier provisions of this Article, an insurer is deemed to be of a Contracting State has, except for the reinsurance, a permanent establishment in the other Contracting State if raised prizes in the territory of that other State or safe against risks in it situated through a person who not be an agent who enjoys one?status? independent to which paragraph 7 applies.

7.Não considers that a company has a permanent establishment in the other Contractor State by the simple fact that you exercise your activity through a broker, general commissioner or any other agent who enjoys an independent "status", provided that these persons act within the normal scope of their activities and that, in their commercial or financial relations with such companies do not paced or impose accepted or imposed conditions that are different from those generally agreed by independent agents.

8.O fact that a resident society of a Contracting State control or is controlled by a resident society of the other Contracting State, or develop its activity in that other State (either through a permanent establishment or otherwise), is not, by itself, sufficient to make any of these societies a permanent establishment of the other.

ARTICLE 6

Real Estate Income

1.Os income that a resident of a Contracting State obtain from real estate (inclusive of the income from agricultural or forestry holdings) located in the other Contracting State may be taxed in that other State.

2.A expression "real estate" will have the meaning that ascribe it to state legislation Contractor in which the goods in issue are situated. Such an expression comprises, in any case, the accessories of real estate, livestock and equipment used in agricultural and forestry holdings, the rights to which the provisions of private law relating to the property of real estate, the enjoyment of real estate and the rights to perceive variable or fixed payments by the holding or concession of the exploitation of mineral deposits, sources and other natural resources ; vessels, vessels and aircraft are not considered real estate.

3.O provisions in paragraph 1 apply to income derived from direct exploitation, rental or of the lease, as well as of any other form of exploitation of real estate.

4.As provisions of paragraphs 1 and 3 also apply to income from goods real estate of a company and of the real estate used for the provisation of independent personal services.

ARTICLE 7

Profits of Companies

1.Os profits from a company of a Contracting State are only taxable in that State, unless the company exercises its activity in the other Contracting State through a permanent establishment situated therein. If the company exercises its activity in the indicated form, its profits may be taxed in the other State, but solely to the extent that they are attributable to that permanent establishment.

2.Ressalvadas the provisions of paragraph 3, when a company of a Contracting State shall exercise its business activity in the other Contracting State through a permanent establishment therein, will be awarded, in each Contracting State, to that permanent establishment, the profits it would obtain if it had constituted a company distinct and separate, which exerted identical or similar activities, under identical or similar conditions, and treated with absolute independence with the company that it is a permanent establishment.

3.Para the determination of the profits of a permanent establishment, it will be permitted to deduct the expenses that they have been made to achieve the purposes of that permanent establishment, including the direction expenses and general administration charges thus carried out either in the State in which the permanent establishment is situated, or guns. However, no payments will be deductible which, in the case, the permanent establishment (other than those effected as reimbursement for effective expenses) to the company's central office or to some of its other subsidiaries, on a "royalty" basis, fees or analogous payments in return for the right to use patents or other rights, on a commission basis, for concrete services rendered or for intakes carried out or, except in the case of a bank, on loan interest to the permanent establishment.

4.Nenhum profit will be awarded to a permanent establishment by the simple fact of the purchase of goods or goods for the company.

5.Quando earnings will understand income treated separately in other Articles of the present Convention, the provisions of these Articles shall not be affected by the provisions of this Article.

ARTICLE 8

Maritime and Air Navigation

1.Os profits from the exploitation of ships or aircraft in international traffic will be taxable only in the Contracting State where the effective direction seat of the company is situated.

2.Se the effective direction seat of a shipping company is located on board a vessel, such a head office shall be deemed to be situated in the Contracting State in which the port of registration of that vessel is found, or, in the absence of port of registration, in the Contracting State in which the person who explores the vessel is located.

3.Os profits as referred to in this Article shall not include the profits earned from the provision of the service of lodging or of a transport activity other than the exploitation of ships or aircraft in international traffic.

4.O provisions of paragraph 1 shall also apply to profits arising from participation in a consortium, joint venture or international operating agency, but only to the extent that such profits are attributable to the participant in the proportion of their share in the joint operation.

ARTICLE 9

Associated Companies

When:

a) a company of a Contracting State participation, directly or indirectly, in the direction, in control or in the capital of a company of the other Contracting State, or

b) the same people participate, directly or indirectly, in the direction, in control or in the capital of a company of a Contracting State and a company of the other Contracting State, and in both cases, the two companies, in their commercial or financial relations, are connected by conditions accepted or imposed that dictate from those that would be established between independent companies, the profits which, without such conditions, would have been obtained by one of the companies, but were not by virtue of such conditions, may be included by a Contracting State in the profits of that company and, consequentially, taxed.

ARTICLE 10

Dividends

1.Os dividends paid by a resident corporation of a Contracting State to one resident of the other Contracting State can be taxed in that other state.

2.Todavia, such dividends may also be taxed in the Contracting State in which it resides society that pays them and in accordance with the legislation of that State, but, if the effective beneficiary of the dividends is a resident of the other Contracting State, the tax thus established shall not exceed:

a) 10% of the gross amount of dividends if the effective beneficiary is a corporation that is owner of at least 20% of the shares with the right to vote of the society that pays such dividends,

b) 15% of the gross amount of dividends in all other cases. This paragraph shall not affect the taxation of the corporation with reference to the profits that give rise to the payment of dividends.

3.O term "dividends" used in this Article designates income from shares, shares of fruition or enjoyment on shares, shares of mining companies, parts of founder or other rights to participate in profits with the exception of credits, as well as income from other social holdings subject to the same tax treatment that the income of shares by the legislation of the State in which the corporation that distributes them is resident.

4.As provisions of paragraphs 1 and 2 shall not apply when the beneficial beneficiary of dividends, resident of a Contracting State, exercise, in the other Contracting State that it is a resident of the corporation that pays the dividends, business activity through a permanent establishment situated in that other Contracting State, or prestain independent personal services by means of a fixed base located in that other Contracting State with which the shareholding of the dividends is effectively linked. In this case, the provisions of Article 7 or Article 14 shall apply, as the case may be. 5.Quando a resident of Mexico maintain a permanent establishment in Brazil, such establishment may be subject to a tax withheld at source in accordance with Brazilian legislation. Such a tax, however, may not exceed the limit set forth in the inciso a) of paragraph 2 of this Article, based on the gross amount of the profits of that permanent establishment, determined after the payment of the corporate income tax concerning those profits.

6.Um Contracting State will not be able to charge any taxes on dividends paid by a corporation which is not a resident of that State, except to the extent that such dividends are paid to a resident of that State or to the extent that the shareholding of the dividends is effectively linked to a permanent establishment or to a base fixed situated in that other state.

7.As provisions of this Article shall not apply when the competent authorities agree that the rights by which dividends are paid have been agreed or established with the principal purpose of taking advantage of this Article. In this case, the provisions of the internal law of the Contracting State of which the dividends are derived shall apply.

ARTICLE 11

Interest

1.Os interest from a Contracting State and paid to a resident of the other Contractor State can be taxed in that other state.

2.Todavia, these interest may also be taxed in the Contracting State of which they originate and in agreement with the legislation of that State, but, if the container is the effective beneficiary of the interest, the tax thus required will not be able to exceed l5 per cent of the gross amount of interest.

3.Não notwithstanding the provisions of paragraphs 1 and 2:

(a) interest coming from a Contracting State and paid to the Government of the other Contracting State, or to one of its political subdivisions, or to its Central Bank, or to any financial institution of exclusive property of that Government or of one of its political subdivisions, are exempt from tax in the first Contracting State, unless the they apply for paragraph "b" ;

(b) the interest in government debt, securities or bonds issued by the Government of a Contracting State, either by one of its political subdivisions, or its Central Bank, or any financial institution of exclusive ownership of that Government are only taxable in that State ;

c) the interest received by a recognized pension fund or pension fund in a State Contractor is only taxable in that State whenever it is the effective beneficiary of the same and their income is generally exempt from tax in that Contracting State.

4.O term "interest" used in this Article means the income of credits of any nature, whether or not accompanied by mortgage guarantees or a clause of participation in the profits of the debtor, and, in particular, the income of government debt, securities or bonds, included the atches and premiums relating to those securities, well as any other income that the state's tax legislation from which they come from assimilates to the income of borrowed importances.

5.As provisions of paragraphs 1, 2 and 3 do not apply when the effective beneficiary of the interest, resident of a Contracting State, exercise, in the other Contracting State that they come from interest, business activity through a permanent establishment therein, or to provide in that other State independent personal services by intermediate of a fixed base there, and the credit in respect of which the interest is paid is effectively linked to that permanent establishment or to that fixed basis. In this case, the provisions of Article 7 or Article 14 shall apply, as the case may be.

6.Os interest is deemed to come from a Contracting State when the debtor is a resident of that state. However, when the debtor of interest, whether or not a resident of a Contracting State, has in a Contracting State a permanent establishment or a fixed basis that assumes the burden of the same, they shall consider themselves as from the State Contractor in which the permanent establishment or the fixed basis is situated.

7.A limitation set out in paragraph 2 does not apply to interest accruing from a State Contractor and paid for a permanent establishment of a company of the other Contracting State situated in a third State.

8.Quando, in consequence of existing special relationships between the debtor and the effective beneficiary of the interest, or between both and third parties, the amount of interest paid, for any reason, to exceed what would be agreed between the debtor and the effective beneficiary in the absence

of such relations, the provisions of this Article shall be applicable only to the latter amount. In this case, the surplus part of the payments shall be taxable, in accordance with the legislation of each Contracting State, taking into account the other provisions of this Convention.

9.As provisions of this Article shall not apply where the competent authorities agree that the credit for which interest is paid, has been agreed or established with the principal purpose of taking advantage of this Article. In this case, the provisions of the internal law of the Contracting State of which they come from interest shall apply.

ARTICLE 12

?Royalties?

1.Os "royalties" coming from a Contracting State and paid to a resident of the other State Contractor may be taxed in that other state.

2.Todavia, these "royalties" may also be taxed in the Contracting State of which they originate, and from in accordance with the legislation of that State, but if the container is the effective beneficiary of the "royalties", the tax thus established will not be able to exceed 15% of the gross amount of the " royalties?.

3.O term "royalties", employed in this Article, means the remunerations of any nature paid for the use or granting of the use of any copyright on a literary, artistic or scientific work, including film films, films or recording tapes used for broadcasting by radio or television, or any other means of reproduction, the reception of, or the right to receive, images or sounds, or both, for the purpose of transmitting them by satellite, cable, fiber optics or similar technology, or the use or concession of use, in relation to television or radio, of images or sounds, or both, to convey them to the public by satellite, cable, fiber optic or similar technology, from a patent, industry or trade mark, drawing or model, plan, formula or secret process or other intangible property as well as by the use or by the granting of the use of an industrial, commercial or scientific equipment, or by information relating to industrial, commercial or scientific experiments.

4.As provisions of paragraphs 1 and 2 do not apply when the effective beneficiary of the "royalties", resident of a Contracting State, exercise, in the other Contracting State of which the "royalties" originate, business activity through a permanent establishment therein, or provide in that other State personal services independent by intermediate of a fixed base therein, with which the right or the generator property of the "royalties" is effectively linked. In this case, the provisions of Article 7 or Article 14 shall apply, as the case shall be.

5.Os "royalties" are considered to come from a Contracting State when the debtor is a resident of that State. However, when the debtor of the "royalties", resident or not of a

Contracting State, has in a Contracting State a permanent establishment or a fixed basis that assume the burden of the same, these consider themselves to be from the State in which the permanent establishment or the fixed basis is situated.

6.Quando, in consequence of special relationships existing between the debtor and the effective beneficiary, or between one and another and third parties, the amount of the "royalties", taking into account the use, right or information by which they are paid, to exceed what would be agreed between the debtor and the effective beneficiary in the absence of such relations, the provisions of the present Article shall apply only to the latter amount. In this case, the surplus portion of the payments may be taxed in accordance with the legislation of each Contracting State, taking into account the other provisions of this Convention.

7.As provisions of this Article shall not apply where the competent authorities agree that the rights by which the "royalties" are paid have been agreed or established with the principal purpose of taking advantage of this Article. In this case, the provisions of the internal law of the Contracting State of which they come from the "royalties" shall apply.

ARTICLE 13

Capital Gains

1.Os gains obtained by a resident of a Contracting State from the disposal of real estate, as per referred to in Article 6, situated in the other Contracting State, may be taxed in that other State.

2.Os gains from the disposal of mobile goods that are part of the asset of an establishment permanent that a company of a Contracting State possesses in the other Contracting State, or of movable property belonging to a fixed basis that a resident of a Contracting State possesses in the other Contracting State for the provision of personal services independent, including the gains arising from the disposal of that permanent establishment (either isolated or with the company set) or from that fixed basis, may be taxed in that other state.

3.Os gains arising from the disposal of ships or aircraft used in international traffic of a Contracting State, or of mobile goods allocated to the exploitation of such vessels or aircraft shall be taxable only in the Contracting State where the company's effective direction office is situated.

4.Nada of the established in this Convention shall affect the application of the legislation Contractor to tax the capital gains arising from the disposal of any other type of property other than that mentioned in this Article.

ARTICLE 14

Independent Personal Services

1.Os income that a resident of a Contracting State obtain by the provision of services professionals or other activities of independent character of an analogous nature are taxable only in that state, unless:

a) remuneration for such services or activities shall be paid by a resident company of the other Contractor State or fall to a permanent establishment or a fixed base located in that other State ; or

b) such services or activities are provided in the other Contracting State and the beneficiary:

i) remain in the other State for one or several periods exceeding, in total, 183 days, in any twelve-month period that starts or ends in the considered fiscal year ; or

ii) have a fixed base available on a regular basis in that other state for the purpose of realizing its activities, however only to the extent that they are attributable to the services carried out in that other state.

4.A expression "professional services" covers, in particular, the independent activities of character scientific, technical, literary, artín-tic, educational or pedagogical, as well as the independent activities of doctors, lawyers, engineers, architects, dentists and accountants.

ARTICLE 15

Dependent Personal Services

1.Ressalvadas the provisions of Articles 16, 18, 19, 20 and 21, wages, wages and other similar remuneration that a resident of a Contracting State receives on the grounds of a job is taxable only in that State, unless employment is exercised in the other Contracting State. If the employment is exercised therein, the corresponding remuneration may be taxed in that other State.

2.Não notwithstanding the provisions of paragraph 1, the remuneration received by a resident of a State Contractor depending on a job exercised in the other Contracting State only are taxable in the first State if:

a) the beneficiary remains in the other State for a period or periods that do not exceed, on total, 183 days in any twelve-month period that begins or ends during the considered fiscal year ;

b) the remuneration is paid by an employer, or on behalf of an employer, who is resident of the first Contracting State ; and

c) the charge of remuneration does not fit either a permanent establishment or a fixed basis that the employer posits in the other state.

3.Não notwithstanding the preceding provisions of this Article, the remunerations received on the grounds of a job exercised on board a ship or aircraft operated in international traffic can be taxed in the Contracting State where the company's effective direction office is situated.

ARTICLE 16

Direction Remuneration

The direction remunerations,?jetons? and other similar consideration received by a resident of a Contracting State as a member of a Board of Directors or Fiscal of a resident society of the other Contracting State may be taxed in that other State.

ARTICLE 17

Artists and Desportists

1.Não notwithstanding the provisions of Articles 7, 14 and 15, the yields obtained by a resident of a State Contracting State of your personal activities exercised in the other Contracting State in the quality of professional of spectacles, such as theatre artist, film, radio or television, or as a musician, or in the quality of sportsmanship, may be taxed in that other state. The income referred to in this paragraph shall include the income that referred to resident obtain from any personal activity exercised in the other Contracting State related to his reputation as an artist or sportsman.

2.Não notwithstanding the provisions of Articles 7, 14 and 15, when the income from personal activities exercised by a professional of spectacles or a sportsman, in that capacity, are awarded not to the professional of spectacles or sportsman, but the other person, these income can be taxed in the Contracting State in which they are exerted the activities of the professional of spectacles or of the sportsman.

ARTICLE 18

Pensions

1.Ressalvadas the provisions of paragraph 2 of Article 19, pensions and other analogous remuneration paid to a resident of a Contracting State on the grounds of an earlier employment, may be taxed only in that State.

2.Entretanto, such pensions and other analogous remuneration can also be taxed in the other State Contracting State if the corresponding payment is effected by a resident of that other State or by a permanent establishment in it situated. 3.Não notwithstanding the provisions of paragraphs 1 and 2, pensions and other payments effected by virtue of an official program integrating the Social Welfare system of a Contracting State or one of its political subdivisions, or of a local administration are taxable only in that state.

ARTICLE 19

Public functions

1.a) The salaries, ordered and other remuneration, excluded pensions, paid for by a State Contractor or one of its political subdivisions or local authorities to a physical person, for services provided to that State or to this subdivision or entity, are taxable only in that State ;

b) However, these salaries, ordered and other remuneration are taxable only in the other state Contractor if the services are provided in that other State and if the physical person is a resident of that other State who:

i) posits the nationality of that State ; or

ii) did not become a resident of that State solely for the purpose of providing the services.

2.a) The pensions paid for by a Contracting State or one of its political subdivisions or entities places, either directly, or by funds by them constituted, to a physical person, on the grounds of services rendered to that State, to that subdivision or entity, are taxable only in that State ; and

b) However, such pensions are taxable only in the other Contracting State if the physical person is resident and national of that State.

3.Aplica-if the provisions of Articles 15, 16 and 18 of this Convention to wages, wages and other remuneration as well as pensions paid on the grounds of services provided in connection with an entrepreneurial activity exercised by one of the Contracting States or one of their political subdivisions or local entities.

ARTICLE 20

Teachers and Researchers

A physical person who is, or was, in period immediately prior to his visit to a State Contractor, resident of the other Contracting State and that, at the invitation of that first Contracting State or a university, or other educational or culture institution of that first Contracting State, or that, by fulfilling an official program of cultural exchange, remain in that State for a period of no surplus to two years, with the sole purpose of teaching, lecturing or conducting research at such institutions, will be exempt from tax in that State for the remuneration of that activity, provided that the payment of such remuneration comes from outside that State.

ARTICLE 21

Students

1.As-matter received to cover expenses with maintenance, studies or training of a student, trainee or apprentice that it is, or was, in period immediately prior to your visit to a Contracting State, resident of the other Contracting State and to remain in the first state mentioned only with the sole purpose of pursuing your studies or your training, will not be taxed in that state, provided that these payments come from sources located outside that state.

2.Em relation to grants, scholarships and employment remuneration not covered by the paragraph 1, students and apprentices in respect of paragraph 1, during the period of such studies or of that training, shall be entitled, ademais, to the same exemptions, rebates or tax reductions, granted to residents of the State who are visiting.

ARTICLE 22

Other Yields

The incomes of a resident of a Contracting State coming from the other Contracting State and not dealt with in the previous Articles of this Convention may be taxed in that other State.

ARTICLE 23

Elimination of Double Taxation

1.Em shall comply with the provisions, and without prejudice to the limitations provided for in the laws of the Contracting States (in accordance with the occasional modifications of such legislations which do not affect their general principles), when a resident of a Contracting State obtain income which, in accordance with the provisions of this Convention, may be taxed in the other Contractor State:

a) the first state, will allow for a credit against the tax on the income of that resident, of a amount equal to the tax on income paid in that other State ; and

b) Mexico will allow its residents to credit against the tax on Mexican income, addressing of a company owning at least 10% of the shares entitled to the vote of a society in Brazil and of which the society mentioned in the first place receives dividends, the tax on income paid to Brazil by the corporation that distributes referred to dividends, or on account of the same, in relation to the profits with reference to which dividends are paid. However, such a credit may not exceed the fraction of the income tax, calculated before credit, corresponding to taxable income in that other Contracting State.

2.Quando, in accordance with any provision of this Convention the yields obtained by a resident of a Contracting State are exempt from the tax in that State, the said State may, however, consider the exempt income for the purpose of calculating the amount of tax on the rest of the income of such a resident.

ARTICLE 24

Non-Discrimination

1.Os nationals of a Contracting State shall not be subject in the other Contracting State to any taxation or corresponding obligation that is not required, amusing or more engraved than that to which they are or can be subject to nationals of that other Contracting State who are in the same situation, in particular, with reference to the residence. Notwithstanding the provisions of Article 1, this provision shall also apply to persons who do not reside in any of the Contracting States.

2.Os permanent establishments that a company of a Contracting State have in the other State Contractor shall not be subjected to taxation less favor than that of the companies of that other State carrying out the same activities. The provisions of this Article shall not be construed in the sense of obliging a Contracting State to grant the residents of the other Contracting State any personal deduction, abatement and reduction for tax purposes in accordance with the State civil or family charges granted to their own residents.

3.A less that the provisions of Article 9, paragraph 8 of Article 11 or of the paragraph 6 of Article 12, the interest, the?royalties? or too much expenses paid by a company of a Contracting State to a resident of the other Contracting State are deductible, in determining the taxable profits of that company, under the same conditions as if there were paid to a resident of the State mentioned in the first place.

4.As companies in a Contracting State whose capital is wholly or partially, directly or indirectly, held or controlled by one or several residents of the other Contracting State, shall not be subject, in the first State, to any taxation or obligation with it not to be required or more engraved than those to which they are or can be subject to the other similar companies of the first state.

5.Não Notwithstanding the provisions of Article 2, the provisions of this Article shall apply to taxes feds of any class or denomination.

ARTICLE 25

Friendlier Procedure

1.Quando a person shall consider that the measures taken by one or both Contracting States conduct, or may conduct, in relation to you, a taxation at odds with the provisions of this Convention, you may, regardless of the resources provided for by the domestic law of those States, submit their case to the authority's assessment competent State of the Contracting State from which it is resident or national.

2.A competent authority, if the complaint appears to be justified and if it itself is not in a condition to provide you with satisfactory solution, you will do everything possible to resolve the matter by friendly agreement with the competent authority of the other Contracting State in order to avoid taxation not complying with this Convention.

3.As competent authorities of the Contracting States will do their best to resolve the difficulties or address the doubts to which the interpretation or application of the Convention can be given.

4.As competent authorities of the Contracting States will be able to communicate directly in order to reach an agreement under the terms indicated in the preceding paragraphs.

ARTICLE 26

Exchange of Information

1.As competent authorities of the Contracting States shall exchange each other with the necessary information to apply the provisions of this Convention or those of the internal legislation of the Contracting States relating to federal taxes established by the Contracting States to the extent that the taxation in it is not contrary to the Convention. The exchange of information applies to federal taxes of any class or denomination and is not limited by Articles 1 and 2. Information received by a Contracting State shall be considered secret in the same manner as information obtained by the application of the domestic legislation of that State and may only be communicated to the persons or authorities (including courts and administrative bodies) in charge of the launch or collection of taxes covered by this Convention, or of the initiation of proceedings on infringements relating to such taxes, or of the appraisal of resources corresponding to them. Such persons or authorities will only use this information for tax purposes.

2.As provisions of paragraph 1 shall not, in any case, be construed in the sense of obligation to a Contracting State to:

(a) take administrative action contrary to its legislation or administrative practice or those of the another Contractor State ;

b) to provide information that could not be obtained on the basis of your legislation or within the framework of your normal administrative practice or those of the other Contracting State ; and

c) provide revealing information of commercial, business, industrial, professional or professional secrecy commercial or industrial process, or information whose communication is contrary to public order.

ARTICLE 27

Diplomatic Employees and Consular

The provisions of this Convention shall not affect the tax privileges of which the benefits of the diplomatic or consular officials be by virtue of general rules of International Law, whether of provisions of special agreements.

ARTICLE 28

Diverse Provisions

1.As competent authorities of both Contracting States will be able to deny the benefits of this Convention, when you so agree under Article 25 of that Convention, to any person or in relation to any operation, if, in your opinion, the or hedging of the benefits of the Convention constitutes an abuse of this Convention considering its object and end.

2.Nenhuma provision of the Convention, except as far as the Article of?Exchange of Information?, will apply:

a) on income that is exempt from tax in a State

Contractor of which the effective beneficiary of the income is resident, or to the earned income by that resident who are taxable in that Contracting State to an aliquot less than the aliquot applicable to the same income obtained by other residents of that Contracting State who do not benefit from that exemption or aliquot ; and

b) to income earned by an effective beneficiary who is a resident of a Contracting State, which enjoys a deduction, restitution or other concession or benefit, which is directly or indirectly relaciated with that income, other than the credit of the foreign tax paid and that does not be given to other residents of that State Contractor.

3.As provisions of this Convention shall not prevent a Contracting State from applying the provisions of its national legislation on insufficient capitalization or to combat deferral, included the legislation of foreign controlled corporations (CFC legislation) or other similar legislation.

4.As provisions of this Convention shall not prevent a Contracting State from applying the provisions of its national legislation relating to the combating of evasion and tax elision or abuse of the Convention, including those applicable to the respaled credits.

5.Não notwithstanding, a person who is not entitled to the benefits of this Convention as per the provisions of paragraphs 1 and 3 may demonstrate to the competent authorities of the State that their right to the benefits of the Convention derive their income from them. For such an effect, one of the factors that the competent authority will take into consideration will be the fact that the establishment, constitution, acquisition and maintenance of such person and the realization of their activities did not have as one of its principal purposes to obtain some benefit in accordance with this Convention.

ARTICLE 29

Input in Vigor

1.Cada one of the Contracting States shall notify the other, in writing, by diplomatic means, that the procedures required by their legislation for the entry into force of this Convention have been complied with. The Convention shall enter into force on the date of receipt of the last notification.

2.A Convention will produce effects:

a) in the case of Mexico, starting on the first day of the month of January of the calendar year following the date on that between in effect ;

b) in the case of Brazil:

i) in respect of taxes withheld at source, to the sums paid or credited in or after the first day of January, inclusive, of the calendar year immediately following that in which the Convention enters into force ;

ii) in respect of the other taxes of which it treats the Convention, in the fiscal year beginning in the first day of January, inclusive, of the calendar year immediately following that in which the Convention enters into force.

ARTICLE 30

Complaint

1.A this Convention shall remain in force for as long as it is not denounced by a Contracting State. Any Contracting State may denounce the Convention by delivering written notice of denunciation to the other Contracting State, by la via diplomatic, with at least six months of anticipation in relation to the end of any calendar year after have transcurated five years from their entry into force.

2.A Convention will cease to produce effects:

a) in the case of Mexico, starting on the first day of the calendar year following that in which the warning ;

b) in the case of Brazil:

i) in respect of taxes withheld at source, to the sums paid or credited in or after the first day of January of the calendar year immediately following that in which the notice of denunciation was given ;

ii) in respect of the other taxes of which it treats the Convention, to the income paid during the year fiscal starting at or after the first day of January of the calendar year immediately following that in which the notice of denunciation has been given. In testimony to what, the undersigned, duly authorized by their respective governments sign the present Convention. Made in Mexico City on this 25 day September 2003, in duplicate, in the Portuguese and Spanish languages, both of which are equally authentic texts.

_____________________________

BY THE GOVERNMENT OF THE REPUBLIC

FEDERATIVE OF BRAZIL

AMORIM CELSO

Minister of Foreign Affairs

_____________________________

BY THE GOVERNMENT OF STATES

MEXICAN UNITED

LUIS ERNESTO DERBEZ BAUTISTA

Secretary of Foreign Affairs

P R O T O O L O

At the time of signature of this Convention between the Governments of the Federative Republic of Brazil and of the United Mexican States intended to Prevent Double Taxation and Prevent Fiscal Evasion in Tax Matters on the Income, the undersigned have been consigned to the following provisions constituting an integral part of the Convention.

1.Com reference to Article 4

a) A society of persons, succession or fideicomit considers itself to be a resident of a State Contractor only to the extent that the income obtaining is taxable in that State as a resident's income, either as income from the people's society, succession or fideicomit, or from its associates or beneficiaries ; and

b) The term?resident? also comprises a Contractor State, one of its political subdivisions or one of its local entities. 2.Com reference to paragraph 4, inciso?e? of Article 5 Activities that have a preparatory or auxiliary character include, among others, the advertising, provision of information, scientific investigations and preparation for the granting of loans.

3.Com reference to Article 7

For the application of paragraphs 1 and 2, the income or gains attributable to an establishment permanent during their existence will be taxed in the Contracting State in which the permanent establishment is situated, even when the payment is deferred until after the said establishment has ceased to exist.

4.Com reference to Article 11

In the case of Brazil, the term?Interest? comprises the interest mentioned in Law No. 9,249 of December 26, 1995, which are paid as a contractual of the reinvested capital (remuneration on equity) and deductible in Brazil.

5.Com reference to Articles 10, 11 and 12

Should Brazil wake up with any other country, after the signing of this Convention, aliquots lower (including exemptions) to those established in these Articles, such aliquots shall apply for the purposes of this Convention, on the same terms, at the time when they enter into force. However, in the case of interest and?royalties?, such aliquots may not, in any case, be less than 4.9% or 10%, respectively.

6.Com reference to paragraph 3 of Article 12

(a) it is understood that the provisions of paragraph 3 of Article 12 apply to any kind of payment received on the grounds of provison of technical assistance and technical services ; and

b) in the event that Brazil accords with any other country, after the date of the signature of the present Convention, a device whereby income from the provision of technical services which does not entail a right to those referred to in the reference paragraph shall be deemed to be income to which Article 7 or 14 applies, dictates provision shall apply automatically in place of the established in the preceding incision of this Protocol, at the time of the entry into force of the Convention containing it.

7.Com reference to paragraph 1 of Article 14

It is understood that the provisions of Article 14 will apply even if the activities are exerted by a society.

8.Com reference to Article 16

It is understood that the yields referred to in this Article include income obtained:

a) in the case of Mexico, by the persons acting in their capacity as administrators or commissioners ; and

b) in the case of Brazil, by the persons acting in their capacity as a member of the board or any of the advice of a society.

9.Com reference to Article 24

a) it is understood that the provisions of Brazilian tax law that do not allow the "royalties", as defined in paragraphs 3 and 4 of Article 12, paid by a permanent establishment situated in Brazil to a resident of Mexico who exercises business activities in Brazil through that permanent establishment, be deductible at the time of determining the taxable income of that permanent establishment, they are not conflicting with the provisions of Article 24 of this Convention ; and

b) it is understood that the provisions of paragraph 5 of Article 10 do not conflide with the provisions of the paragraph 2 of Article 24 of this Convention.

10.Com reference to Article 25

Notwithstanding any other treaty, agreement or convention in which the Contracting States are or come to be parties, any tax situation between the Contracting States, including a dispute regarding the implementation of this Convention, shall be resolved solely in accordance with this Article 25 unless the competent authorities have another form.

In testimony to what, the undersigned, duly authorized by their respective Governments sign the present Convention.

Made in Mexico City on September 25, 2003, in two original copies, in the languages Portuguese and Spanish, being both equally authentic texts.

_____________________________

BY THE GOVERNMENT OF THE REPUBLIC

FEDERATIVE OF BRAZIL

AMORIM CELSO

Minister of Foreign Affairs

_____________________________

BY THE GOVERNMENT OF STATES

MEXICAN UNITED

LUIS ERNESTO DERBEZ BAUTISTA

Secretary of Foreign Affairs