CONTROL TEST: When the taxpayer has the effective control or control of the administration of the foreign entity (to the extent, that he can decide the moment of the distribution of income or dividends, either directly or through another person) by reason of an average participation per day in the foreign entity. As an anti-fragmentation rule, it is required to add up the average participation per day of related parties and closely-related-individuals regardless where they reside.  OTHER: It applies to foreign legal entities, transparent entities and any kind of arrangement. It does not apply to PEs held directly by the Mexican taxpayer, since the income of such PEs should be accrued by the Mexican taxpayer by reason of other chapters of the law.