Mexico’s current Foreign Investment Law (FIL) establishes, as a general rule, that except in the case of activities exclusively reserved to the Mexican Nation, foreign private capital may participate at a one hundred percent (100%) level in the capital of Mexican entities. Notwithstanding such, there are stillvarious activities for which the direct participation of foreign capital is either prohibited or restricted to a pre-determined limit.In some of these cases, however, the FIL allows for exceptions via the authorized use of neutral investment. Neutral investmentgrants limited or no corporate rights to the owners of such shares and is not computed, for legal purposes, as foreign investmentin the capital of a Mexican entity. Neutral investment can be used with respect to (i) activities that are reserved to Mexicanindividuals or Mexican entities that do not admit foreign owners, such as certain transportation services, retail sale of gasolineand distribution of liquefied petroleum gas, radio broadcasting and television services, credit unions, development banks andcertain professional and technical services; and (ii) regulated activities that admit a limited percentage of foreign investment,such as domestic air transportation services, insurance and bonding institutions, currency exchange, bonded warehouses,ownership of Series “T” shares representing agricultural, cattle, or forest land contributed to a Mexican company, cable andtelephone services, fisheries and port administration.

On September 4, 2006 the Organic Law of the Attorney General for Taxpayer Defense was published in the Official Journal of the Federation (Diario Oficial de la Federación), which has as its purpose regulating the organization and functioning of the office of the Attorney General for Taxpayer Defense, in order to guarantee the right of taxpayers to be treated fairly in tax matters at the federal level through advising, representation and defense; receipt of complaints; and the issuance of guidelines and recommendations. The Attorney General for Taxpayer Defense is a decentralized, unaffiliated public entity with its own legal personality and assets, and it is also technically, functionally and materially autonomous. Services that will be provided by the Attorney General’s office will be offered exclusively upon the request of interested taxpayers, will be free of cost, and will include, among other things, advising and consulting on issues presented by taxpayers in relation to actions taken by federal tax authorities; representing taxpayers before corresponding tax authorities; providing said service with the office’s own administrative resources and, as the case may be, providing representation before the Federal Tribune of Fiscal and Administrative Justice; as well as attending to taxpayer complaints made in relation to actions carried out by federal tax authorities for presumed violations of their rights; and, as the case may be,proposing independent recommendations to the public.