On November 7th, 2025, the Federal Revenue Law for Fiscal Year 2026 (“LIF”, per its acronym in Spanish) was published in the Official Gazette of the Federation (“DOF”, per its acronym in Spanish), along with amendments to the Federal Tax Code (“CFF”, per its acronym in Spanish), the Special Tax on Production and Services Law (“LIEPS”, per its acronym in Spanish), and the Federal Duties Law (“LFD”, per its acronym in Spanish).
Federal Revenue Law for Fiscal Year 2026
Hydrocarbons
Exemption from the Customs Processing Fee (“DTA”, per its acronym in Spanish) for the importation of natural gas.
Interests
An annual withholding rate of 0.90% is established on interest payments, applicable to the financial system for interest paid to their clients and to other payers when covering interest to individuals.
For the deduction of uncollectible accounts, credit institutions must record cancellations no later than June 2026 and observe specific rules for loans secured by mortgage guarantees.
A 9% withholding applies to nominal interest defined as the agreed premium in securities lending transactions.
Collective financing institutions (crowdfunding) must withhold and remit Income Tax (“ISR”, per its acronym in Spanish) at a rate of 20% on the amount of nominal interest paid to contributors.
Digital Platforms
Technological platforms (domestic or foreign) that act as intermediaries and collect payments on behalf of third parties must withhold 2.5% from legal entities that sell goods or provide services through them, based on the income collected, without deductions. The withheld tax is creditable against provisional payments or the annual tax liability. If the legal entity does not provide its Federal Taxpayer Registry (“RFC”, per its acronym in Spanish) to the platform, the platform must withhold 20%.
Platforms that collect payments on behalf of third parties must withhold Value Added Tax (“IVA”, per its acronym in Spanish) from Mexican legal entities in accordance with the Value Added Tax Law (“LIVA”, per its acronym in Spanish), withhold 100% of the VAT when the supplier is a foreign resident without a permanent establishment that sells in Mexico or when payments are deposited into foreign accounts, and must remit the withholdings, issue Digital Tax Receipts via Internet (“CFDI”, per its acronym in Spanish) for the withholdings, and provide monthly information on transactions and counterparties.
Insurance Companies
The VAT transferred on the acquisition of goods or the provision of services, as well as the VAT paid on imports, will not be creditable when such goods or services are intended to fulfill an insurance contract and the indemnity is granted to repair damages or to replace the insured asset through third parties, in accordance with the Insurance Contract Law.
Insurance companies may credit the VAT transferred on goods or services received up to December 31st, 2024, when such goods or services are used to fulfill insurance contracts whose indemnity consists of compensating damages or replacing the insured asset through third parties.
A tax incentive equivalent to the credited VAT or to the VAT tax credit (including updates, fines, surcharges, and expenses) may be obtained by taxpayers under audit powers without a final resolution at the time of entry into force, or with challenged VAT tax credits, provided they withdraw the legal remedy or dispute resolution mechanism previously filed, subject to compliance with certain requirements.
Tax Incentives
Subject to compliance with certain requirements, the following incentives are provided:
Incentive consisting of a credit against ISR for the same fiscal year in which the diesel, biodiesel, and their blends imported or acquired, equivalent to the Special Tax on Production and Services (“IEPS”, per its acronym in Spanish) incurred on the sale or paid upon importation. Applicable to taxpayers with annual income for ISR purposes of less than sixty million pesos, provided that, to determine their taxable income, they may deduct such fuels and that they are used exclusively as fuel in general machinery, except vehicles. This also applies to marine vehicles.
Quarterly refund of the creditable amount for legal entities under the agricultural and forestry regime, with limits per partner or associate and caps based on the Unit of Measure and Update.
Credit of the IEPS for diesel or biodiesel used in vehicles intended exclusively for the transport of people or cargo.
Credit of up to 50% of toll expenses for taxpayers engaged in public or private ground transportation of cargo, passengers, and tourism, with annual income below three hundred million pesos.
Credit of the amount resulting from multiplying the applicable IEPS rate by the volume of fuel consumed in productive processes in which the fuel is not burned.
Credit of the special mining duty paid during the fiscal year by holders of concessions or assignments with annual gross income from the sale or transfer of minerals and substances of less than fifty million pesos.
Additional deduction of 8% of inventory costs for individuals and legal entities residing in Mexico whose total income in the previous fiscal year was less than or equal to six million pesos and whose income from the sale of such goods represents at least ninety percent of the total.
Beginning in the last quarter of 2025, people participating in the organization and celebration of competitions, trials, matches, and events related to the International Federation of Association Football World Cup 2026 will not be subject to the formal obligations of payment, transfer, withholding, collection, and remittance arising exclusively from such acts or income derived from their participation.
Regularization and Repatriation of Capital
Self-correction mechanism for taxpayers with income below three hundred million pesos in fiscal year 2024 who are not classified as Large Taxpayers, applicable to finalized or accepted tax liabilities, consisting of up to 100% forgiveness of fines, surcharges, and enforcement costs, subject to the filing of an application and compliance with established requirements. During the process, the Administrative Enforcement Procedure (“PAE”, per its acronym in Spanish) is suspended without the need for a guarantee, and the statute of limitations is paused. Excluded from this benefit are, among others, individuals convicted of tax crimes and taxpayers listed under Articles 69-B or 69-B Bis.
Funds held abroad as of September 8th, 2025, may be repatriated by paying a 15% tax rate without deductions, on a definitive basis, and must be invested in Mexico for a period of three years.
Federal Tax Code
Digital Tax Receipts Via Internet
Denial of registration in the RFC to legal entities linked to Companies that Issue Simulated Invoices (“EFOS”, per its acronym in Spanish) and Companies that Deduct Simulated Invoices (“EDOS”, per its acronym in Spanish) when their representatives, partners, or key individuals are related to invoicing simulation schemes and have not corrected their situation.
CFDIs may only cover real transactions and valid legal acts; false invoices produce no tax effects and trigger administrative and criminal penalties.
Shortened verification procedure, intended to confirm that CFDI cover existing, genuine transactions or actual legal acts; it provides for the immediate suspension of CFDI stamping upon notification, 5 business days to present evidence, a resolution within 15 business days, and a maximum duration of 24 business days; the use of photos, audio, and video is permitted.
Issuers of false CFDIs will be published on official websites, and recipients will have 30 calendar days to correct their situation through amended tax returns or face temporary restriction of their Digital Seal Certificate (“CSD”, per its acronym in Spanish).
CFDI related to hydrocarbons and petroleum products must include the valid permit number; omissions or errors may lead to restriction of the CSD and presumptions of illegal trade.
The deadline to cancel a CFDI is extended until the month in which the annual ISR return for the year of issuance is filed, subject to the recipient’s acceptance.
Tax Simplification
The Tax Administration Service (“SAT”, per its acronym in Spanish) centralizes verification and authentication when an advanced electronic signature is used as a means of identification or digital signing; the requirements will be detailed through regulations.
Under the Simplified Trust Regime (“RESICO”, per its acronym in Spanish), monthly payments become final, and an annual tax return is no longer required
Administrative review or reconsideration is only applicable against resolutions determining tax liabilities, on a single occasion and when no legal remedies are in progress.
Reduced fines for RESICO taxpayers in specific cases.
Extension to 20 business days to notify precautionary seizures.
Strengthening of the Tax Authority’s Powers
New causes for restriction or cancellation of CSD, such as unpaid finalized tax liabilities, disproportionate amounts invoiced, inconsistencies between tax returns, CFDIs, and bank statements, significant infractions, and noncompliance in the hydrocarbons sector.
Expanded access to financial information from all types of entities and to data storage media, to support audits and presumptions.
Presumption of income from unregistered deposits for individuals not registered or without accounting records, applying an annual threshold exceeding $2,028,610.00, from which income is presumed.
Suspension or cancellation in the RFC due to prolonged inactivity, including objective parameters and cancellation upon the death of individuals.
Notaries and public attestors must confirm the authenticity of documents when requested by the authority.
Digital platforms must provide online and real-time access to operational information; failure to comply may result in blocking of the platform.
Use of photographs, audio, and video during audits and inspections, with evidentiary value.
The authority must inform the taxpayer, their representative, and governing bodies of its findings; the taxpayer must provide and keep the governing body’s data up to date.
The tax authority may request information with a standardized order, methodology, and characteristics to link transactions, including banking data.
Registered public accountants must report potential noncompliance or crimes detected in their audit reports.
Payment in installments of tax liabilities in customs matters is allowed.
New infractions and penalties for noncompliance with volumetric controls and reporting obligations.
Infraction for conditioning the issuance of CFDI on the Tax Situation Certificate or for recording an RFC different from that of the purchaser.
The appeal for revocation is inadmissible when the filer is unaware of the challenged act.
Mandatory order to secure the tax interest and requirement of a guarantee to obtain suspensions; the exemption from guaranteeing the federal government’s fiscal interest when filing an appeal for revocation is eliminated.
New infraction for altering closure seals or continuing operations during a closure, with an increased closure period.
Tax and Foreign Trade Crimes
Commercialization or possession of foreign goods without documentation proving legal stay, without tax stamps or seals on alcoholic beverages, or without valid security codes on cigarettes and nicotine products are considered as smuggling offenses, this includes false or altered codes and false certificates of origin used to obtain preferential treatment.
A new crime is established for providing false information or forged documents in tax procedures, punishable by imprisonment and the obligation to repair damages.
New smuggling behaviors are defined, including simulation in temporary imports or returns, shortages or non-arrival by authorized warehouse operators or transporters, and improper withdrawals from bonded warehouses; penalties are adjusted to higher ranges.
Sanctions are established for digital platforms and holders that facilitate the sale or purchase of false CFDIs or that cover nonexistent or simulated transactions.
Special Tax on Production and Services Law
Nicotine and Manufactured Tobacco
The tax rates applicable to manufactured tobacco are increased, and a new specific quota of $1.1584 per cigarette sold or imported is established, to be applied gradually from 2026 to 2029.
The definition of other products containing nicotine is incorporated, including those with natural or artificial nicotine, regardless of their form or presentation, that do not contain cut, ground, or leaf tobacco and are not designed to be heated or burned.
The tax rate is determined based on the nicotine content, considering 8 milligrams per taxable unit. Products used as nicotine replacement therapy with sanitary registration are excluded.
Producers and importers of cigarettes, manufactured tobacco, and nicotine products must annually register price lists by brand and presentation, and must report monthly the prices, values, and volumes of sales, specifying the weight or milligrams subject to tax. Likewise, they must maintain physical controls of the volume produced or packaged and report quarterly the readings of the measuring devices used to the tax authority.
Flavored Beverages
Flavored beverages will be subject to a rate of $3.0818 per liter when they contain added sugars and $1.5000 per liter when they contain sweeteners. In the case of concentrates, powders, syrups, essences, or extracts, the tax will be calculated based on the number of liters that can be obtained according to the manufacturer’s specifications.
The tax will not apply to medicines with sanitary registration, milk in any presentation, including those mixed with vegetable fat, or oral rehydration solutions containing all substances provided for by law.
Digital Services: Gambling/Raffles and 18+ Video Games
Games involving bets and raffles conducted by foreign residents without a permanent establishment in Mexico are incorporated as taxable subjects; they must register, collect, remit, and file monthly returns for the corresponding tax, based on the amounts received.
A tax rate of 8% is imposed on the sale and provision of digital services related to video games with violent, extreme, or adult (18+) content, including freeaccess games that offer additional in-game content.
When sold through memberships or subscriptions that include other services without itemization, it is presumed that 70% of the total amount corresponds to such video games.
Digital intermediary platforms that collect payments on behalf of third parties must withhold 100% of the IEPS, and failure to comply with these obligations may result in temporary service suspension.
Accrual and Crediting
The tax is incurred upon actual payment of consideration, with specific bases per unit of measure (grams, milligrams, liters, or units), and credit is allowed for the tax paid on imports. In the case of cigarettes, nicotine products, and manufactured tobacco, withdrawal from the plant or warehouse is considered a sale when the goods are not intended for commercialization.
Federal Duties Law
Telecommunications and Spectrum
For purposes of contributions related to telecommunications and the use of the radio spectrum, a new institutional framework is established through the creation of the Telecommunications Regulatory Commission, which is granted authority to study, authorize, and share frequency bands among departments and entities of the Federal Executive Branch, as well as to issue regulations regarding diplomatic exemptions managed by the Ministry of Foreign Affairs.
Fee Adjustments and Sectoral Facilities
For the determination of fees related to the use, enjoyment, or exploitation of the radio spectrum, concessionaires may access discounts subject to compliance with geographic coverage obligations or based on their status as small operators, in accordance with the joint provisions issued by the Telecommunications Regulatory Commission and the Ministry of Finance and Public Credit.
The applicable amounts for fees in migration, health, aviation, financial, cultural, and public health matters are specified, and specific rules are incorporated for the production and control of tax stamps, seals, and operations of the National Institute of Copyright.
Criteria are established for the measurement and annual determination of fees for temporary authorizations and orbital segmentation, linked to the valuation methodology.
Entry into Force
For the purposes of applying the tax provisions corresponding to fiscal year 2026, the LIF, the CFF, the LIEPS, and the LFD will enter into force on January 1st, 2026, except for those provisions that, by their nature, establish a later implementation or execution schedule.
Particularly, for the LIF, the self-correction facilities and finalized tax credits will operate during 2026, with applications due by January 31st and correction or payment by March 31st, 2026; for the CFF, online access to digital platforms will take effect on April 1st, 2026; for the IEPS, the per-cigarette rate will gradually increase from 2026 to 2029, with full application beginning in 2030; and for telecommunications, entry into force will occur upon the establishment of the Plenary of the new Telecommunications Regulatory Commission, under an interim regime administered by the IFT.
Conclusion
The 2026 Tax Amendments represents a profound transformation of Mexico’s tax framework, aimed at strengthening revenue collection, improving tax oversight, and promoting transparency in the management of public income. While it introduces relevant incentives for specific productive sectors and administrative simplification mechanisms, it also significantly expands the tax authority’s powers of control and sanction, increasing compliance obligations for taxpayers and digital platforms.
At Ibarra del Paso Gallego, we are prepared to face the challenges and opportunities brought by the 2026 Tax Amendments and their implications. Our objective is to anticipate risks, assess the fiscal and operational impact on our clients, ensure regulatory compliance, and anticipate defense mechanisms when necessary.
Our tax practice team has experience in tax consulting, planning, compliance, and litigation, enabling us to provide strategic guidance and comprehensive solutions in the face of new regulatory scenarios. We work proactively to ensure that our clients maintain legal certainty, operational efficiency, and a strong position in light of the provisions taking effect in 2026.
