Tax regulations that will come into force in 2026, establish new procedures for guaranteeing tax assessments owed by individuals and Corporations.   Starting in January, specific and mandatory conditions for ensuring payment of tax assessments are established, in order of priority, in the event of challenges through administrative and/or judicial proceedings.   Article 141 of the Federal Tax Code now mandates a specific order of alternatives to guarantee tax interest. The fir

Among the most relevant changes in tax regulations that will take effect in the next fiscal year, 2026, the one concerning the fight against the issuance and acquisition of fake invoices stands out.   A new audit mechanism has been established in Article 49-Bis of Mexico´s Federal Tax Code, which will be carried out through inspections when SAT suspects that invoices issued by Companies do not cover legitimate transactions. This is an "express" audit that entails the temporar

Mexico´s Tax Administration Service (SAT) recently shared its criteria to conduct taxpayer audits, emphasizing that there is no list of individuals who will be subject to door-to-door visits, and urging citizens not to fall for scams circulating on social media.   The elements that will be prioritized for initiating tax audits are the following:   ·       Conducting transactions with shell companies that record/invoice false transactions to avoid tax obligations, or those tha

The Supreme Court of Mexico (SCJN), as a result of the Contradiction of Criteria 120/2025 ruling, has established/defined binding precedents on social security matters and recognizes that, in relation to the 2025 INFONAVIT reform, which incorporated Employer´s obligation to maintain salary deductions for employees with housing loans, are on medical leave from IMSS or absent from work, it is appropriate for employers to suspend salary deductions for the payment of said loans w

Companies established in Mexico are required annually to self-determine its workers' compensation insurance premium to be used during the fiscal year in order to comply with Social Security contributions obligations to the Mexican Social Security Institute (IMSS).   However, we have detected cases in which IMSS, unilaterally and through an administrative resolution, corrects or reclassifies the workers' compensation premium upwards, causing harm to companies by forcing them t

Tax authorities have audit powers to verify compliance with taxpayers' tax obligations; these powers are established in the Federal Tax Code and are exercised through audits.   We have detected an increase in these powers, particularly in foreign trade audits, leading to significant tax assessments that could permanently affect companies.   There are alternative solutions that could be useful in the early stages of the audit. Advance Dispute Resolutions (Settlement Agreements

Article 22 of the Federal Tax Code establishes the process that a taxpayer (individual or legal entity) must follow to obtain a tax refund when a credit balance is generated in their tax returns. However, we have documented cases in which the tax authority makes excessive information requests and unilaterally withdraws the applicants' requests, or, worse yet, denies them the refund through an appealable resolution.   At TP Legal, we sponsored a significant case in which a com

The process of suspending and subsequently canceling taxpayers' Digital Seal Certificates in Mexico (CSD) has become increasingly common (and, not to mention, effective for the authorities). The CSD is elemental to issue an invoice (Digital Fiscal Receipt – CFDI) for any transaction carried out by companies.   The process is pre-established in Article 17-H Bis of the Federal Tax Code; however, the authorities have increasingly implemented cases whose clarification process has

Registration in the Business Certification Scheme (CIVA) for VAT and IEPS has been, since its inception, an incentive for taxpayers, as it allows them to generate a tax credit equivalent to 100% of the amount owed for these taxes in the case of specific transactions.   However, CIVA, in addition to providing benefits, entails ongoing obligations that all those who benefit from the certification must comply with. Therefore, we have detected a considerable increase in cases in