As the main rule of the Mexican CFC legislation, the CFC's income needs to be subject to an income tax that is equivalent to at least 75% of the income tax that would have been paid in Mexico. Income taxed at a statutory rate of at least 22.5%, provided that all income is taxable, except dividends paid between entities that are residents of the same jurisdiction and that their deductions have been actually incurred. Royalties received by foreign entities for the use or concession of use of a patent or industrial secrets, provided that some conditions are met. Our control test is set as an exclusion (see question 4). Income derived from restructuring operations, under certain conditions. Mexican authorities can authorize Mexican residents not to apply CFC legislation if the controlled entity has authorization to act as a financial institution in the country it resides.