On December 28th, 2025, the Miscellaneous Tax Resolution for 2026 (“RMF”, per its acronym in Spanish) was published in the Official Gazette of the Federation (“DOF”, per its acronym in Spanish). The RMF contains the general rules issued annually by the tax authority to clarify and operationalize the provisions set forth in tax laws, establishing procedures, requirements, and criteria applicable to the fulfillment of tax obligations.
General Provisions
- The structure, title, and content of the RMF Annexes were updated, incorporating adjustments to catalogs, regulatory compilations, technical annexes, and control annexes, in order to harmonize them with the current tax reforms.
Federal Tax Code
- As a result of the inflationary update, fines, amounts related to tax offenses, enforcement expenses, and thresholds related to the tax audit opinion and tax situation report are updated.
- The late-payment surcharge rate applicable as of 2026 was increased to 2.07% per month.
- The tax authority will verify that the taxpayer has not been published as an issuer of false tax receipts; if the taxpayer falls under such circumstance, the compliance opinion will be negative, even if the taxpayer is current on payments. Likewise, taxpayers are allowed to authorize third parties to consult their compliance opinion.
- The issuance of false tax receipts prevents access to tax benefits and constitutes grounds for revocation of authorizations, including those already granted.
- Validation procedure for legal entities whose registration in the Federal Taxpayers Registry is denied due to having partners, shareholders, legal representatives, or board members who fall under circumstances involving nonexistent transactions or issuance of false tax receipts, among others.
- Activities related to the production, preparation, bottling, manufacturing, or importation of flavored beverages that use sugars or sweeteners are incorporated as economic activities subject to registration.
- The circumstances requiring the obligation to keep volumetric controls are expanded, incorporating the transportation or storage of hydrocarbons or petroleum products for own use.
- A rule is added establishing the requirements and conditions that expert reports must meet when used to rebut presumptive determinations of gross income in activities related to hydrocarbons and petroleum products.
- The cancellation of CFDIs without the express acceptance of the recipient is restricted, and the obligation is established to issue CFDIs with specific requirements for the sale of gasoline and diesel, including the use of the corresponding complement.
- New obligation in the issuance of CFDIs for taxpayers that sell gasoline and diesel, who must comply with the specific procedures and requirements provided for such purposes.
- Incorporation of a requirement to obtain and retain authorization to operate as a CFDI certification provider, consisting of not having been considered an issuer of false tax receipts, which constitutes a new ground for revocation.
- Obligation to keep accounting systems solely by the fact of receiving donations, regardless of whether or not authorization exists for such donations to be deductible for income tax purposes.
- The procedure is adjusted so that legal entities requesting to know the facts or omissions detected during audit powers must accompany documentation that allows the information provided to be corroborated; failure to do so will be understood as the taxpayer not wishing to exercise such right.
- Taxpayers published pursuant to Article 69 of the CFF may request clarification and provide evidence to rebut their situation; the SAT will only publish taxpayers who, in addition to being not located, present systematic noncompliance with tax obligations, and will update this information on a quarterly basis.
- Taxpayers that provide digital services, directly or indirectly, must grant the SAT online access to detailed information on their operations; such information must be kept for 5 years, be available through a username and password, and be provided no later than April 30th, 2026, or the month following the start of activities.
- The obligation of the registered public accountant is expanded, who must report in the tax audit opinion any noncompliance with tax or customs provisions, and not only those that could constitute offenses.
- The restriction that prevented requesting payment in installments or reduction of fines with respect to contributions and government charges derived from foreign trade operations is eliminated.
- When it is not possible to guarantee the tax interest in accordance with the legal order, the taxpayer must prove such impossibility through account statements, registry documentation, and an affidavit.
- Possibility to request reduction of fines for noncompliance in matters related to CRS, FATCA, and beneficial owner.
- It is allowed to correct payroll CFDIs issued in 2025 with errors, provided that the substitute CFDI is issued and the incorrect one is canceled no later than February 28th, 2026.
Income Tax
- The circumstances under which uncollectible accounts may be deducted due to notorious practical impossibility of collection are regulated.
Value-Added Tax
- The requirements and procedure to apply the tax incentive related to VAT credited up to December 31st, 2024, are established, including updates, surcharges, fines, and enforcement expenses.
- Collective Financing Institutions that pay interest must issue withholding CFDIs, incorporating the Interest Complement, stating the VAT withheld.
Special Tax on Production and Services
- The nicotine content in products other than cigarettes must be calculated in milligrams and divided by 8 to determine the IEPS quota base, harmonizing the treatment of vaporizers and similar products.
- Producers and importers of cigarettes and other nicotine-containing products must register the list of sale prices in the MULTI-IEPS program together with the declaration for the first month of the fiscal year and report detailed information by brand and presentation.
- The procedure for the delivery of stamps and seals is modified; these must be collected within a maximum period of 30 calendar days counted from the day following the one on which the notification of the authorization letter takes effect.
- Various grounds for removal from the Alcoholic Beverages Taxpayer Registry are incorporated and specified, among which stands out that the taxpayer has a final resolution by which the tax authority has determined the issuance of tax receipts for nonexistent transactions.
Other Relevant Changes
- With respect to the tax regularization program, the procedure to verify the income limit of 300 million Mexican pesos in 2024, is established, especially for non-profit entities intending to apply the tax incentive.
- The procedures to pay income tax for the repatriation or return of resources held abroad and returned to the country are regulated.
- Operational and tax rules applicable to foreign participants, host issuer, service providers, players, transferred persons, and volunteers in the FIFA World Cup 2026 are established, defining exempt income, income subject to income tax, and the treatment for VAT and IEPS.
- The informational obligations of digital intermediation service providers are strengthened, including monthly information on operations even when consideration is not charged, and a specific report for games with bets and raffles taxed with IEPS.
- No guarantee is required for appeals for revocation filed before 2026.
