Matus Ruiz & Romero Apis — 2026 Tax Reforms: Revenue Law, IEPS, and Federal Tax Code

In its evening edition of November 7, 2025, the Official Gazette of the Federation published the following key instruments for fiscal year 2026:

Decree issuing the Revenue Law for Fiscal Year 2026.
Decree amending, adding, and repealing various provisions of the Federal Tax Code.
Decree amending and adding various provisions of the Special Tax on Production and Services Law.
Decree amending, adding, and repealing various provisions of the Federal Fees Law.

Below is our executive summary of the most relevant points:

Revenue Law for Fiscal Year 2026

The relevant aspects are the following:

Surcharges for extensions of tax assessments (which had not changed since 2018): a monthly rate of 1.38% on outstanding balances is established. For installment payments, the following surcharges are established: 1.42% (up to 12 months), 1.63% (more than 12 months and up to 24 months), and 1.97% (more than 24 months).
Withholding and remittance of income tax on interest paid by the financial system and interest paid to individuals (except payments made by insurance institutions to insured parties or their beneficiaries): a rate of 0.90% on principal is established.
Three-fourths of the ordinary and extraordinary contributions paid by multiple banking institutions in Mexico under the Bank Savings Protection Law will not be deductible. We consider that this limitation has constitutional defects.
The special rule for the deduction of bad debts by credit institutions in Mexico is eliminated. The rules are now aligned with the general corporate regime. This modification could violate the principle of tax equity by “treating unequal parties equally.”
The withholding rate is increased to 2.5% that must be applied by legal entities resident in Mexico or non-residents with or without a permanent establishment in the country, as well as foreign legal entities that directly or indirectly provide the use of technology platforms, software applications, and similar services. Technology platforms are also obligated to withhold 2.5% from legal entities resident in Mexico on income obtained from the sale of goods and services through those platforms. The withheld tax will be creditable against the income tax payable in the provisional payments of the relevant fiscal year. If certain obligations are not met, the withholding rate will be 20%.
An obligation is incorporated at the federal statutory level for Collective Financing Institutions (“Crowdfunding”) to: i) withhold and remit income tax at a 20% rate on nominal interest paid to individuals and legal entities that contributed resources to financing operations (withholding applies to non-residents); and ii) withhold and remit the corresponding VAT on those payments. The withholding must be applied at a 16% rate on the nominal value of accrued interest. They must also provide information on interest paid under Article 55 of the Income Tax Law.
The obligation is imposed and extended on non-residents and legal entities resident in Mexico to withhold VAT from legal entities (resident in Mexico) that sell goods, provide services, or grant the temporary use or enjoyment of goods through digital services described in Article 18-B, Section II of the VAT Law, among others.
Institutions comprising the financial system that act as intermediaries in securities lending transactions (which are not a sale for tax purposes) must withhold, as a provisional payment, at a 9% rate on nominal interest (agreed premium). The same rule will apply to investment funds in debt instruments and equity funds (applying the 9% withholding on nominal interest).
New rules apply to foreign transparent legal entities.
General incentive for the forgiveness of 100% of penalties, surcharges, and collection costs: A benefit is established for individuals and legal entities whose cumulative income in fiscal year 2024 did not exceed MXN $300 million, consisting of the forgiveness of 100% of penalties, surcharges, and collection costs derived from tax assessments determined by the SAT or the ANAM, whether own, withheld, or passed through. This incentive will apply provided that taxpayers: i) pay the total updated tax assessment in a single installment no later than December 31, 2026, or ii) in the case of assessments observed during audit powers, self-correct before the corresponding procedure concludes, among other requirements.
Tax incentive for participants in the 2026 FIFA World Cup: Individuals and legal entities resident in Mexico or abroad, including those with a permanent establishment in the country, that participate in the organization and celebration of the 2026 FIFA World Cup, as well as its tests, matches, and related events, will not be subject to tax obligations related exclusively to the acts, activities, or income derived from their participation.

Reform to the Special Tax on Production and Services Law

The following points were reformed:

The reference to “manufactured tobacco” is expanded to “manufactured tobacco and other products.” The applicable rates are also updated, increasing the tax on cigarettes to 200%, cigars and other manufactured tobacco to 200%, cigars and other manufactured tobacco made entirely by hand to 32%, and other nicotine-containing products to 100%.
The applicable quotas for manufactured tobacco and other products are updated, increasing progressively from fiscal year 2026. For that year (second transitional provision), the quota will be $0.8516; for fiscal year 2027, $0.9197; for fiscal year 2028, $0.9932; for fiscal year 2029, $1.0726; and for fiscal year 2030, $1.1584. These quotas will not be subject to the updating mechanism referred to in the fourth paragraph of subsection C), Section I of Article 2 of the Law.
A new classification is incorporated for other nicotine-containing products, adding to the applicable quota an amount equal to the result of dividing the nicotine content by 0.8, regardless of whether the nicotine is natural or artificial.
It is specified that the flavored beverages category includes beverages containing added sugars or sweeteners, whether natural or artificial. Beginning in fiscal year 2026, the applicable per-liter quotas are updated: $3.0818 for beverages with added sugars and $1.50 for beverages with sweeteners. Energy drinks containing added sugars or sweeteners of any kind will also be taxed at the applicable rates, without prejudice to the IEPS applicable to them as energy drinks. From our perspective, this new IEPS on beverages with sweeteners has constitutional defects.
Subsection K is added to Article 2, Section I, taxing at an 8% rate the sale in national territory of video games with violent, extreme, or adult content, unsuitable for persons under 18 years of age, when sold in physical format to the general public. For imported video games, that rate does not apply.
The tax applicable to the use of games with betting and lotteries is increased to 50%, regardless of whether they are conducted over the internet or electronic media, directly by the digital service provider or through domestic or foreign digital intermediation platforms.
The mechanics for determining the monthly payment are established. For cigarettes, manufactured tobacco, and nicotine products, the tax will be determined based on the per-unit quota, weight divided by 0.75, or nicotine content divided by 0.8. For flavored beverages and derivatives, the quota per liter sold or obtainable liters will apply.
An 8% IEPS is imposed on digital services that allow access to or download in national territory of video games with violent, extreme, or adult content (unsuitable for persons under 18 years of age), when provided by: (i) non-residents without an establishment in Mexico, or (ii) residents in Mexico under Article 18-B, first paragraph and Section I of the VAT Law.
Article 5-A Bis is incorporated, establishing that digital platforms that collect the price and IEPS for intermediation services must withhold 100% of the IEPS incurred by service providers, with such withholding considered a final payment.
The removal of cigarettes, tobacco, or other nicotine products from the place of manufacture or warehouse is considered a sale when they are not intended for commercialization and are packaged.
Sales to the general public of beer, soft drinks, cigarettes, cigars, tobacco, and nicotine products are not taxed, except when the seller is a manufacturer, producer, bottler, distributor, or importer; nor are flavored beverages sold in restaurants and food establishments, or beverages with a health registration as medicines, milk in any presentation, and oral rehydration solutions, in accordance with the Law.
Subsection j) is added to Article 8, Section I, establishing that nicotine products used as replacement therapies with a health registration as medicines are not taxed.

Reforms to the Federal Tax Code

The following was reformed:

Section XIV was added to subsection C of Article 27 of the Federal Tax Code to empower the SAT to deny RFC registration to legal entities when it detects that their legal representative, partners, or members have participated in companies with “serious” tax backgrounds, namely: failure to rebut the temporary restriction on invoicing (17-H, X), “invoicing” companies for nonexistent operations (17-H, XI), improper transfer of losses (17-H, XII), issuance of false invoices (17-H, XIII), or companies published for final assessments, for being non-located, for a conviction, or for using or giving effects to CFDIs of nonexistent operations without demonstrating materiality (Article 69, twelfth paragraph, Sections I, III, IV, and IX; 69-B); it will also apply if such persons are part of another legal entity in those cases and have not corrected their situation, in order to prevent new companies from being used to continue improper operations.
It was established as a requirement for digital tax receipts that they cover existing operations, true facts, or real legal acts. It is further specified that receipts that do not cover existing operations, true facts, or real legal acts are considered false. (Article 29-A, Section IX).
Subsection g) was added to Section V of Article 42 of the Federal Tax Code to empower the authority to verify compliance with the veracity of digital tax receipts and to make a determination regarding the issuance of false tax receipts.
It was established that when taxpayers who received false tax receipts have not reversed the corresponding tax effect, the authority may temporarily restrict the use of the digital seal certificate to issue digital tax receipts.
Article 29-A, fourth paragraph, of the Federal Tax Code was reformed to establish that taxpayers may cancel the digital tax receipts they issue no later than the month in which the annual income tax return must be filed, which is currently established as an administrative facility in general rule 2.7.1.46 of the 2025 RMF. We consider that, although this reform is positive, the deadline remains insufficient, and therefore constitutional defects exist.
It was specified that the resolutions subject to administrative reconsideration are those determining tax assessments, so that a request for administrative review of any other type of resolution would be inadmissible.
Section XII was added to Article 17-H Bis of the Federal Tax Code to establish as a ground for temporary restriction of the digital seal certificate when taxpayers have final tax assessments that have not been fully paid together with their accessories, provided that in the fiscal year immediately preceding the restriction they issued tax receipts for a total amount exceeding four times the historical amount of the tax assessment.
The assumptions of Article 17-H Bis for the temporary restriction of the digital seal certificate were also expanded. New grounds include: the commission of customs infractions; failure to meet requirements in hydrocarbon and petroleum product CFDIs (such as failing to declare the permit key of the National Energy Commission or declaring an incorrect one); and taxpayers that have given tax effects to receipts issued by “invoicing” companies definitively listed under Article 69-B, if they do not correct their tax situation by reversing those effects within 30 calendar days.
Article 17-H Bis, Section VII of the Federal Tax Code was reformed so as not to refer only to bank account statements, since using the term “bank” is limiting in a context where taxpayers may hold deposit accounts at other types of financial institutions.
Article 45 of the Federal Tax Code was reformed to establish, as part of the obligations of audited persons, allowing tax authority inspectors to verify account statements corresponding to accounts opened at a financial entity generally, and not only statements issued by banking institutions.
A second paragraph was added to Section VI, subsection C, of Article 27 of the Federal Tax Code to require notaries to opine, when requested by the SAT, on the authenticity of public instruments submitted by taxpayers, and to empower the SAT to establish the applicable procedure through general rules, in order to deter forged documents and provide greater legal certainty in tax procedures.
Article 30-B of the Federal Tax Code was added to establish the obligation of digital service providers to allow tax authorities permanent, online, real-time access to information in their systems or records related to the digital services they provide. This obligation will enter into force on April 1, 2026.
A third paragraph was added to Article 42 of the Federal Tax Code to establish that, in exercising audit powers under the Code, tax authorities may authorize the use of technological tools to generate photographs, audio, or video of the proceedings they conduct, regarding facts and omissions learned and assets discovered under the respective order.
Article 48, second paragraph, of the Federal Tax Code was reformed to clarify that when the authority is exercising audit powers, it may request reports, data, documents, accounting or part thereof, as well as economic and financial information, with the order, methodology, and characteristics that allow the taxpayer’s operations, acts, or activities to be related.
Sections X, XI, and XII were added to Article 124 of the Federal Tax Code to establish new grounds for inadmissibility of the revocation appeal. With this reform, the appeal will be inadmissible when filed against administrative acts that: the taxpayer claims not to know; require payment of tax assessments determined in liquidation resolutions that have already been challenged and became final by resolution of a competent authority; or resolve requests regarding the statute of limitations of such final tax assessments.
Article 141, first paragraph, of the Federal Tax Code was reformed to establish a mandatory order for the forms in which taxpayers may secure the tax interest (deposit certificate).
Article 141, Section I of the Code was reformed to add the deposit certificate evidencing a cash deposit issued by an authorized institution. Although the obligation to secure the tax interest through a deposit certificate is initially established, that obligation is not absolute; the possibility that the debtor’s financial capacity may not allow securing the entire liability in that manner is recognized, thereby making the initial obligation more flexible and allowing a combination of guarantee forms according to the taxpayer’s particular situation.
The guarantee based on securities and loan portfolios was eliminated.
It is established that, in revocation appeals, the federal tax interest must be secured. However, under the Twenty-Ninth Transitional Article of the 2026 Revenue Law, taxpayers filing the appeal from January 1, 2026, may post such guarantee within six months following the filing of the appeal, or within ten days after the resolution notification takes effect, if the resolution is issued before that period ends.
The conduct of producers, manufacturers, and importers of cigarettes and other manufactured tobacco, except cigars and other manufactured tobacco made entirely by hand, who fail to print the security code on each cigarette pack for sale in Mexico is assimilated to the crime of smuggling.
Article 115 Ter was added to punish anyone who, knowingly, declares false facts or data, or submits false or altered documentation in any of the procedures established in the Federal Tax Code.

This communication is provided for informational purposes only as an executive summary and should not be considered professional advice. With collaboration from Stephanie Uribe, Ana M. Tinoco, Ian F. Montes, and Francisco Salazar.