On December 29, 2025, the Miscellaneous Tax Resolution was published in the Official Gazette of the Federation. It entered into force on January 1, 2026, and will remain in effect until December 31 of the same year.

The Miscellaneous Tax Resolution (MTR) contains general provisions applicable to taxes, products, uses, contributions for improvements, and federal duties, excluding those related to foreign trade. Its purpose is to facilitate taxpayers’ timely and proper compliance with their tax obligations.

Its function is limited to detailing and clarifying the corresponding regulations, without correcting legal provisions or procedures, nor imposing additional obligations beyond those established by law. Nevertheless, we acknowledge the possibility of exceptions in cases where the Legislature has granted specific powers to the Tax Administration Service (SAT) through the so-called “enabling clause.” In such cases, the authority must adhere to the scope established by said clause, always respecting the principles of hierarchical subordination.

The purpose of this document is to provide general information on the most relevant and novel aspects of the 2026 MTR, without conducting an exhaustive analysis or including all applicable rules. In each case, it is recommended to review the specific effects and consequences of the MTR.

Federal Tax Code

Rule 2.1.6 Non-working days

For the purposes of Article 12, first and second paragraphs of the Federal Tax Code (FTC), the following shall apply:

I. The non-working days for the SAT shall be April 2 and 3, 2026.

Rule 2.1.12. Updating of amounts established in the Federal Tax Code.

The Miscellaneous Tax Resolution (MTR) for 2026 establishes, under Rule 2.1.12 (section XVII), the procedure for updating various amounts set forth in the Federal Tax Code (FTC), in accordance with the indexation mechanism provided in Article 17-A, sixth paragraph.

Main updating procedure (Article 17-A, sixth paragraph of the FTC)

Amounts are updated when the accumulated percentage increase in the National Consumer Price Index (NCPI) since the month of the last update exceeds 10%.

• Period considered for the threshold: November 2022 (NCPI = 125.997) to February 2025 (NCPI = 138.726).
• Accumulated increase: (138.726 / 125.997) – 1 = 10.10% → exceeds 10%.
• Effective updating period: November 2022 to December 2025.
• Base NCPI: November 2022 = 125.997.
• Final NCPI: November 2025 = 142.645 (published in the Official Gazette of the Federation on December 10, 2025).
• Updating factor: 142.645 / 125.997 = 1.1321 (equivalent to a 13.21% increase).

This factor is applied to the amounts established in various provisions of the FTC (fines, penalties, thresholds for tax crimes, enforcement expenses, limits on deductible donations, among others), as detailed in Annex 5, Section A, Subsection I of the 2026 MTR. The updated amounts enter into force as of January 1, 2026.

Additional specific updates.

• For the amounts set forth in Articles 32-A, second paragraph, and 32-H, section I, first paragraph of the FTC: the procedure established in the third paragraph of Article 32-A and the second paragraph of section I of Article 32-H was applied, using an annual updating factor (November 2024 to November 2025).
  • NCPI November 2024 = 137.424.
  • NCPI November 2025 = 142.645.
  • Factor: 142.645 / 137.424 = 1.0379 (approximately 3.79%). These amounts are detailed in Annex 5, Section A, Subsection II.

In summary, the update responds to the legal obligation to preserve the real value of tax-related amounts in light of accumulated inflation exceeding 10%, applying the factor of 1.1321 as the primary multiplier (and 1.0379 in specific cases), effective as of January 1, 2026.

Rule 2.1.20 Monthly surcharge rate.

For the purposes of Article 21 of the Federal Tax Code (FTC), the monthly surcharge rate for overdue payment applicable for fiscal year 2026 shall be 2.07%.

Rule 2.1.36 Procedure to obtain the tax compliance opinion

Taxpayers who are required to obtain a tax compliance opinion must follow the procedure set forth below.

Through this rule, the possibility is established for a supplier or service provider to authorize, through the SAT portal, a third party with whom it intends to enter into contractual relationships to consult its tax compliance opinion.

For purposes of issuing the tax compliance opinion, the SAT will verify that the requesting taxpayer has not been issued and notified of a resolution determining that it has issued false tax receipts.

Rule 2.1.51 Exception to bank secrecy

This rule establishes that any request for information made by the tax authority (SAT) pursuant to Article 32-B, section IV, second paragraph of the Federal Tax Code constitutes an express exception to the ordinary procedure set forth in Article 142 of the Credit Institutions Law (LIC).

The SAT’s request does not require mandatory intermediation by the National Banking and Securities Commission (CNBV), nor does it need to follow the general channel provided for in Article 142 of the LIC.

The SAT may request the information directly from financial institutions (or through the channels indicated in Article 32-B of the FTC).

Bank secrecy is not violated, since the LIC itself (Article 142, section IV) already provides for an exception for tax purposes in favor of the federal tax authorities.

Rule 2.2.1 Evidentiary value of the password.

The password shall be valid for four years, counted from the date of its generation or its most recent update, and must be renewed through any of the means made available by the SAT.

The generation, update, or renewal of the SAT password must be carried out in accordance with the corresponding procedure forms for individuals (712/CFF) and legal entities (31113/CFF) set forth in Annex 1-A2.

If the procedure is carried out in person, the SAT may request additional information and documentation to verify the identity, domicile, and tax status of the applicant, legal representative, partners, or shareholders, and will issue an acknowledgment of receipt of such request.

If the SAT has already accepted the taxpayer’s clarification, the company (legal entity) must generate, update, or renew its SAT password using its e. Signature directly through the SAT Portal, following procedure 13/CFF – Request for generation, update, or renewal of the password for legal entities, as described in Annex 2.

Exceptions

Companies operating under the IMMEX program in the shelter (Albergue) modality may not carry out this procedure online; therefore, they must appear in person at the SAT offices and follow the procedure indicated in the corresponding filing form.

Rule 2.4.17 Procedure for validation of information due to denial of registration in the Federal Taxpayer Registry (RFC) for legal entities

Through this new rule, an exceptional procedure is established, applicable when the SAT denies the registration of a legal entity in the RFC due to the linkage of its legal representative, partners, shareholders, or other members of its organizational structure with situations involving serious tax risk (such as issuers of false tax receipts (EFOS), nonexistent transactions, taxpayers not located, final tax liabilities without guarantees, among others), in accordance with Article 27-C, Section XIV of the Federal Tax Code (FTC).

Procedure flow (step by step)

1. Notification of the denial
   The SAT delivers to the legal representative of the legal entity a document entitled “Acknowledgment pursuant to Article 27, Section C, subsection XIV of the FTC.”
2. Term to refute the situation
   As of the business day following receipt of the acknowledgment, the legal entity has 10 business days to submit, before the competent administrative unit of the SAT, the documentation proving that the detected tax irregularity has been refuted. This must be carried out in accordance with filing form 167/CFF (“Submission of information related to the request for registration in the RFC, pursuant to Article 27, Section C, subsection XIV of the FTC”), contained in Annex 2 of the 2026 MTR.

3. Suspension of the registration term
   The term to resubmit the application for registration in the RFC (Article 23, second paragraph of the Regulations to the FTC) shall be suspended, on a one-time basis, until the SAT issues the official response derived from the information submitted.
   Important: This suspension does not apply if a new registration application is submitted without previously refuting the irregularity (i.e., the term cannot be restarted indefinitely).
4. Authority’s response
   The SAT must issue a response within 10 business days, counted from the business day following receipt of the written submission with the supporting documentation. The applicant must personally appear at the Deconcentrated Taxpayer Services Administration (ADSC) where the submission was filed in order to learn of the resolution.
5. Possible resolutions
   • If the situation is successfully refuted: The SAT issues an official letter stating that the irregularity has been corrected. In this case, the legal representative must submit a new application for registration with the RFC (with a prior appointment), complying with the requirements set forth in the corresponding filing forms.
   • If the situation is not refuted or no information is submitted within the 10-day period: The original registration application shall be deemed not filed. The taxpayer retains the right to submit a new registration application at a later time, without prejudice to the SAT’s authority to deny it again if the risk conditions persist.

Rule 2.7.1.34 Acceptance by the recipient for the cancellation of CFDIs

This rule is amended in its third paragraph to clarify that, in the case of income/expense CFDIs that include the Hydrocarbons and Petroleum Products Complement, or income CFDIs with a Carta Porte that include specific fuel product codes (Diesel 15101505, Regular gasoline 15101514, Premium gasoline ≥91 octane 15101515), the recipient must expressly accept the cancellation for it to be valid.

Rule 2.7.1.35 Cancellation of CFDIs without the recipient’s acceptance

This rule is amended in sections I, III, and IV to establish that taxpayers are not exempt from requiring the recipient’s acceptance of the CFDIs in the following cases:

• Section I: When dealing with CFDIs referred to in Rule 2.7.1.34, third paragraph, as well as CFDIs that include the Payment Receipt Complement referred to in Rule 2.7.1.32.
• Section III: For expense CFDIs, except for those referred to in Rule 2.7.1.34, third paragraph.
• Section IV: For transfer CFDIs, except for those CFDIs with a Carta Porte complement in which the “ClaveProdServ” field indicates, as the product code for the goods and/or merchandise being transported, “15101505” Diesel fuel, “15101514” Regular gasoline with less than 91 octane, and “15101515” Premium gasoline with 91 octane or higher.

Rule 2.7.1.48 Cancellation of CFDIs without the recipient’s acceptance

For purposes of complying with Articles 29 and 29-A of the Federal Tax Code (FTC), taxpayers who sell gasoline and diesel (as indicated in section II of Rule 2.6.1.1) must include in their electronic invoice (CFDI) the Concept Complement for the invoicing of Hydrocarbons and Petroleum Products published by the SAT on its website. It is important to note that this complement has not yet been published.

Additionally, the corresponding product code must be included in the “ClaveProdServ” field of the invoice, depending on the product sold:

• 15101505 – Diesel fuel
• 15101514 – Regular gasoline (less than 91 octane)
• 15101515 – Premium gasoline (91 octane or higher)

Rule 2.7.5.8 Payroll CFDIs to be issued by employers who hire senior citizens or persons with disabilities

For purposes of Article 186 of the Income Tax Law (ITL), taxpayers who wish to apply the tax incentive for hiring senior citizens aged 65 or older or persons with disabilities, in addition to complying with the requirements set forth in said article, must state in the “Concept” field of the “Earnings” node of the payroll CFDI the legend “Payroll payment – Senior citizen” or “Payroll payment – Disability certificate,” as applicable, for each type of earning, according to the type of incentive being applied.

Cancellation of Transfer-Type CFDIs with Carta Porte Complement When Transporting Gasoline or Diesel

For purposes of Article 29-A, fourth paragraph of the Federal Tax Code (FTC), transfer-type CFDIs that include the Carta Porte Complement and indicate in the “ClaveProdServ” field any of the following codes for the goods or merchandise being transported—“15101505” (Diesel fuel), “15101514” (Regular gasoline with less than 91 octane), or “15101515” (Premium gasoline with 91 octane or higher)—may be cancelled without requiring the recipient’s acceptance, provided that the cancellation is carried out from the moment of issuance and before the transportation begins.

Once this period has elapsed, such CFDIs shall be deemed non-cancellable. Likewise, once the transportation has begun, it will no longer be possible to issue a new transfer-type CFDI with the Carta Porte Complement to document the same movement.

Rule 2.9.16 Procedure for consulting the lists of taxpayers referred to in Articles 69-B and 69-B Bis of the FTC.

For purposes of Article 69, twelfth paragraph, section III of the Federal Tax Code (FTC), the SAT will only publish on its website those taxpayers who, in addition to being classified as not located, also show systematic non-compliance with their tax obligations.

Previously, the SAT could publish all taxpayers classified as not located in the corresponding list under Article 69 of the FTC.
Under this rule, publication is restricted solely to those taxpayers who meet both of the following conditions simultaneously:

• Being classified as not located (nonexistent or non-locatable tax domicile).
• Showing systematic non-compliance with tax obligations (for example, failure to file returns, failure to keep accounting records, recurring omissions, etc.).

This represents an improvement for taxpayers who, due to temporary or accidental circumstances, were not located but remain compliant with their tax obligations, as they will not be automatically included in the public list.

Rule 2.9.20 Procedure for consulting the lists of taxpayers referred to in Articles 69-B and 69-B Bis of the FTC

For purposes of Articles 69-B and 69-B Bis of the Federal Tax Code (FTC), taxpayers who wish to consult the lists published by the SAT reflecting the situations contemplated in said articles may do so by following the procedure described below:

• Access the SAT Portal → Procedures and Services → More Procedures and Services.
• Select Risk or Vulnerable Activities → Articles 69-B and 69-B Bis of the FTC.
• Choose the list you wish to consult:

a) Article 69-B of the FTC

• Presumed
• Definitive
• Refuted
• Favorable court ruling

Individual taxpayer inquiry: Go to Additional Materials → Related Content → Individual inquiry of the list of taxpayer notifications and definitive lists. You will be redirected to the SAT website (https://www.gob.mx/sat) → Actions and Programs → General → Notification of taxpayers with presumed nonexistent transactions and definitive lists, where you may view and download the official notices, annexes, and publication dates (SAT and Official Gazette of the Federation).

b) Article 69-B Bis of the FTC

• Global Definitive List

Changes to filing forms.

Among other things, the numbering of the following annexes has been amended:

• Annex 2, formerly Annex 1-A, contains the tax filing forms.
• Annex 3, which contains the compilation of non-binding criteria on tax practices (the annex is now titled Improper Practices).
• Annex 4, formerly Annex 19, contains the updated amounts established in the Federal Duties Law for 2026.
• Annex 18, which contains the tax financial statements audit report (SIPRED 2025), Type I, formerly Annex 16.
• Annex 19, which contains the tax financial statements audit report (SIPRED 2025), Type II, formerly Annex 16-A.

Final recommendations

We consider it of utmost importance to review the entire document published in the Official Gazette of the Federation in order to analyze each of the provisions contained therein.

At LR García Accountants, we have a team of experts who can assist your companies in complying with any tax obligations.

We remain at your disposal for any questions or clarifications in this regard.