September 30th is the deadline to apply the 100% reduction in fines, surcharges, and enforcement costs.

The 2025 Revenue Law provides a tax incentive for a 100% reduction in fines, surcharges, and enforcement costs. The main requirements to qualify for the program are:

1. If you are an individual or legal entity whose total income in the fiscal year in question did not exceed 35 million pesos.
2. Whether it concerns fines imposed for violations indicated in tax, customs and foreign trade laws; fines derived from non-compliance with tax obligations other than payment obligations: fines with aggravating circumstances, as well as with respect to surcharges and execution costs related to own federal contributions, withheld or transferred, or with compensatory quotas, whose administration and collection corresponds to the Tax Administration Service or the National Customs Agency of Mexico, and
3. No forgiveness, reduction, decrease or any other similar benefit would have been received based on the previous programs.
4. Do not have a final conviction for committing any tax crime.
5. Not being published in the lists of articles 69-B or 69-B Bis of the Federal Tax Code.

The application for the incentive is subject to submission of the application by September 30, 2025, as well as the filing of the corresponding tax returns, which must show the updated amounts omitted. The corresponding payment must be made in a single installment, no later than December 31, 2025.

This is a great opportunity for taxpayers to catch up on their tax obligations. We are available to assist you every step of the way.

On September 8, 2025, the Federal Executive Branch submitted to the Chamber of Deputies the Initiative with Draft Decree amending and adding various provisions of the Special Tax on Production and Services Law.

Below we present a summary of the most interesting proposals.

• Increase the tax rate from 160% to 200% on cigars, cigarillos, and other manufactured tobacco. For cigars manufactured entirely by hand, the rate will be increased from 30.4% to 32%, as well as a gradual increase in the specific tax on sold cigars.

• Establish a 200% tax rate for the sale or import of other products containing nicotine, with a specific quota based on the milligram content of natural or artificial nicotine.

• Maintain the exemption from the sale of cigarettes, cigars, and other tobacco products by persons other than manufacturers, producers, or importers.

• Tax flavored beverages with added natural or artificial sweeteners, within the definition of flavored beverages.

• Adjust the rate from 30% to 50% applicable to gambling and raffles, which will also apply to those conducted online or electronically, directly by the digital service provider or national and international digital platforms.

• Tax at an 8% rate the sale to the general public of violent, extreme, or adult content not suitable for minors under 18 years of age in physical format, as well as services provided by nationals or foreigners that allow access to or download of such video games within the country.

• For video game service providers without a business in Mexico, similar obligations are established for digital platforms of foreign residents in the Value Added Tax Law, as well as for intermediaries.

On September 8, 2025, the Federal Executive Branch submitted to the Chamber of Deputies the Federal Revenue Bill for fiscal year 2026.

Below, we present a summary of the most interesting proposals.

• Update the surcharge rate to 1.38% per month on outstanding balances, 1.42% per month for installment payments of up to 12 months, 1.63% for installments of more than 12 months and up to 24 months, and 1.97% per month for installments of more than 24 months.

• Maintain the benefit of reduced fines for violations arising from non-compliance with tax obligations other than payment, depending on the timing of the self-correction, as well as maintaining the 50% discount on the corresponding fine, after the start of verification powers but before the final report or observation letter, and 40% in electronic review.

• Maintain various tax incentives, such as those for the purchase of diesel or biodiesel and their blends, for taxpayers dedicated exclusively to public and private land transportation, whether freight or passenger, as well as tourism, who use the National Toll Highway Network, or who sell books, newspapers, and magazines.

• Increase the fixed withholding rate on the capital amount that gives rise to interest payments by the financial system to 0.90%.

• Maintain support for individuals who pay taxes under the RESICO system and are exclusively dedicated to the primary sector, with the goal of paying income tax only on their income, and solely on the amount exceeding 900 pesos.

• Non-deductibility of fees paid to IPAB by commercial banking institutions.

• Standardize the treatment of the deduction for bad debts applicable to credit institutions with that of other taxpayers, eliminating their special treatment.

• Increase the income tax withholding rate for individuals to 2.5% for the sale of goods and provision of services through electronic platforms and establish a withholding rate of 4% for legal entities, and even 20% in cases where they do not provide their RFC key to digital platforms.

• Extend the obligation to withhold VAT to national and foreign digital intermediation platforms in the following cases:
  • To legal entities under the same terms as to natural persons.
  • To residents abroad without a permanent establishment in Mexico who sell assets in national territory.
  • To suppliers of goods and services in national territory when payments are deposited into bank or deposit accounts abroad.

• Expand the information that digital platforms must provide to the SAT.

• Establish that the provisional withholding of ISR for interest on securities lending transactions be made on the premium paid to the lender and not on the principal amount.

• Relax the requirements for granting private equity funds investments in the domestic market, thus granting them fiscal transparency, in order to shift the administrative and financial burden of tax payment obligations to their constituents, members, or investors, allowing the funds to focus exclusively on their corporate purpose.

• Maintain the tax regularization program for legal entities and individuals to facilitate the payment of debts, increasing the limit on their total income to 300 million pesos.

• Grant facilities for the repatriation of capital held abroad until September 8, 2025, consisting of paying income tax at a rate of 15% without any deductions, on the condition that the capital is invested in productive activities in the country and that, in the event of distributing dividends or making capital repayments over a three-year period, 20% of the income tax is withheld from individuals instead of 10%.

• Relieve tax and administrative burdens on individuals and corporations participating in the organization of the 2026 FIFA World Cup.

On September 8, 2025, the Federal Executive Branch submitted to the Chamber of Deputies the Initiative with Draft Decree amending, adding to, and repealing various provisions of the Federal Tax Code. This amendment contains several important changes regarding audit powers, online digital tax receipts, the processing of appeals for revocation, and the guarantee of fiscal interest.

The most relevant proposals are the following:

Digital Tax Receipts over the Internet (CFDIs).

• Power of the tax authority ("SAT") to deny registration in the RFC to legal entities when it detects that the legal representative or one or more of the partners, shareholders or associates and other persons that form part of its organizational structure have incurred in cases of restriction digital seals, improper transmission of tax losses, issuance of false digital tax receipts, having firm tax credits, that are found to be unlocated, among others.

• Expressly establish as a requirement for CFDIs, which cover existing, genuine transactions or real legal acts, that in the event of exercising any verification power, the tax authority may verify their veracity, as well as the addition of a new power to verify compliance with the veracity of the CFDIs, from which the issuance of CFDIs may be suspended.

• Establish the month in which the annual income tax return must be filed as the deadline for the cancellation of CFDIs.

Administrative reconsideration.

• Note that it only applies to resolutions determining tax credits.

Strengthening the powers of the tax authority.

• Add as reasons for temporary restriction of the digital seal certificate:

• Have outstanding tax credits that have not been fully paid, provided that, in the immediately preceding fiscal year, they have issued CFDIs for a total amount exceeding four times the historical amount of the tax credit.
• Deliberate use of erroneous information in CFDIs related to the marketing of hydrocarbons.
• Failure to respond to requests for information regarding foreign trade.

• It empowers the authority to request information related to accounts opened not only in credit institutions, but also in financial institutions in general, as well as to presume, unless proven otherwise, that deposits in accounts opened in the latter are income and the value of acts or activities.

• Specify the cases in which the cancellation of the RFC is appropriate due to the taxpayer's inactivity.

• Establish the obligation of service providers through digital platforms to allow the tax authority permanent, real-time online access to the information held in their systems and records.

• Implementation of the use of technological tools in the exercise of verification powers, allowing photographs, audio recordings, or videos to be attached to the minutes drawn up.

• The appointment for reporting the facts or omissions discovered in the exercise of verification powers is modified, so that it will be carried out within a maximum period of ten business days after notification of the minutes or observation letter where they are recorded.

• Establish the possibility that, in a cabinet review, the authority may require reports, data, documents, accounting records or part thereof, as well as economic and financial information, in the order, methodology, and characteristics that allow for the relationship between the taxpayer's transactions, acts, or activities.

• Allow deferred or installment payment of tax credits in customs matters.

Infractions and sanctions.

• Incorporate as a violation, making the issuance of CFDIs conditional on the display of the Tax Identification Card.

Appeal for revocation.

• Add as a reason for inadmissibility of the appeal, when the taxpayer states that he is unaware of the appealed act.

Guarantee of fiscal interest.

• Consider that the sufficiency of the guarantees of the fiscal interest will be from their offer and not from their acceptance.

• Establish a mandatory order in the ways in which taxpayers can guarantee tax interest, the first being the deposit note issued by the Banco del Bienestar SNC. The pledge or mortgage is adjusted and the tax interest guarantee accounts, securities, as well as the credit portfolio are eliminated.

• Eliminate the possibility of not guaranteeing the fiscal interest in the appeal for revocation and establish the obligation to do so in federal administrative litigation and amparo proceedings in accordance with the proposed priority.

Tax and foreign trade crimes.

• Assimilate to the crime of smuggling the conduct in which producers, manufacturers, and importers of cigars and other manufactured tobacco fail to print the security code on each pack.

• Adding as a crime, failure to prove the non-arrival of foreign trade merchandise to the general deposit warehouse due to an act of God or force majeure.
• Add four new presumptions of the crime of smuggling.