MEXICO Trends and Developments Contributed by: Luis Ignacio Martel and Jorge A. Cabello, Martel
On 7 November 2025, the Decree enacting the Federal Revenue Law for Fiscal Year 2026 ( Ley de Ingresos de la Federación ) was published in the Official Gazette of the Federation ( Diario Oficial de la Federación ), along with the Decrees amending, adding to, and repeal - ing various provisions of the Federal Duties Law ( Ley Federal de Derechos ), the Federal Tax Code ( Código Fiscal de la Federación ), and the Special Tax on Pro - duction and Services Law ( Impuesto Especial sobre Producción y Servicios ), respectively. From its inception, the initiative submitted to Con - gress was aimed at optimising tax collection, updating special taxes, and refining tax procedures. An analysis of these initiatives reveals a clear trend toward the consolidation of fiscal policy, with a strong emphasis on revenue-collection efficiency, the expan - sion of the captive tax base, and the adaptation of legal frameworks to emerging economic and tech - nological realities. In practice, these measures also entail an implicit restriction of certain legal remedies that were previously available to taxpayers, which – when considered in conjunction with the reforms to the Judiciary and the amendments to the Amparo Law ( Ley de Amparo ) enacted in late 2025 – create an environment of heightened legal uncertainty for taxpayers, whose best option from now on appears to be negotiating with the tax authorities in administra - tive instances, including tax mediation requests filed before the Mexican Tax Ombudsman ( Procuraduría de la Defensa del Contribuyente ). Below is a summary of the most important aspects of the reform and the prevailing trends in Mexico. Digital Platforms Income tax withholding A new obligation has been established for digital intermediation platforms, requiring them to withhold income tax at a rate of 2.5% on legal entities that obtain income from the sale of goods and the provi - sion of services through technological platforms, soft - ware applications, and similar means. If such legal entities fail to provide their tax ID number ( Registro Federal de Contribuyentes ) to the digital platforms, a 20% withholding rate shall apply.
In the case of individuals, the withholding rate has been increased from 1% to 2.5% with respect to the sale of goods and the provision of services. Real-time review of digital platforms As of 1 April 2026, providers of digital services must allow the tax authorities online, real-time access to the information contained in their systems or records that enables verification of the proper compliance with tax obligations. Audits/Revenue Collection Verifications conducted by public notaries and other attesting officers The Mexican Tax Administration Service ( Servicio de Administración Tributaria – SAT) has been granted the authority to establish, through general administrative rules, the procedure to require a public notary or other attesting officer to certify, under oath, the authenticity of the documents submitted by individuals and legal entities in the tax procedures they request. Guarantee of tax liabilities The procedure for providing a guarantee of the tax interest has been amended through the introduction of a new mandatory order of priority that must be fol - lowed for such purposes, as set forth below: • certificate of deposit, issued by an authorised institution; • letter of credit issued by an institution authorised by the National Banking and Securities Commis - sion ( Comisión Nacional Bancaria y de Valores ) and duly registered for such purpose with the SAT; • pledge, excluding intangible assets, and mortgage, excluding real estate with the characteristics of rural land; through general administrative rules, the SAT may establish the characteristics and other types of assets that may be offered under any of these modalities; • surety bond issued by an authorised institution, which shall not enjoy the benefits of order and excussion; • joint and several obligation assumed by a third party that proves its suitability and solvency; and • administrative attachment of ongoing businesses, tangible movable assets, and real estate, excluding those with the characteristics of rural land; the SAT
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