Last Monday, September 8, the Federal Executive delivered to the Mexican Congress the Economic Package 2026, which includes several initiatives that reform, add or repeal certain provisions of multiple laws such as the Federal Law of Rights, the Law of Special Tax on Production and Services (IEPS), as well as the Fiscal Code of the Federation. The aforementioned package includes the proposed Federal Revenue Law and the draft Decree of the Federal Expenditure Budget for the Fiscal Year 2026.
In addition, this package includes a report on the use of the constitutional authority granted to the Federal Executive in tariff matters.
Therefore, the following is a brief summary of the most relevant aspects of the Economic Package for Fiscal Year 2026.
I. ECONOMIC INDICATORS:
Within the General Economic Policy Criteria for the Revenue Law Initiative and the Expenditure Budget Bill for 2026, there are the indicators, as well as the evolution of the Mexican economy that the administration has considered in the planning and preparation of the 2026 Economic Package.
- Local environment.
In Mexico, despite the uncertainty generated by the trade policy with the United States, economic activity grew 0.3% in the first half of 2025 with respect to the previous half, accumulating growth of 0.9% in seasonally adjusted figures.
Macroeconomic indicators have remained solid, highlighting an increase in labor income above its historical average. The exchange rate has shown greater competitiveness during 2024, with the Mexican peso appreciating 10.3% at the end of July to 18.88 pesos per dollar.
Mexican exports are expected to benefit from a more competitive position vis-à-vis other nations in the context of the implementation of new tariffs by the United States.
Primary activities recorded a 2.5% half-year growth, driven by favorable weather conditions, despite the phytosanitary challenges affecting livestock production.
On the other hand, industrial activity decreased 0.4% with respect to the previous semester, reflecting the challenges faced by the manufacturing sector, which barely grew 0.1% in the same period, affected by persistent trade uncertainty.
As for the services sector, a half-yearly growth of 0.5% was observed.
Inflation stood at an annual average of 3.9%. According to the Survey of Expectations of Economic Specialists in the Private Sector, prepared by Banco de México, the 12-month projection remains at 3.6%, while for the end of 2026 it is estimated at 3.8%.
Foreign trade indicators reflect a 4.3% annual increase in the value of exports, driven by a more competitive real exchange rate. This growth occurred despite a 4.5% annual drop in automotive exports, affected by international trade policy.
On the other hand, imports registered an annual growth of only 0.5% between January and July 2025. It is worth noting that non-oil imports increased 1.2%, due to a higher demand for intermediate goods. However, there was a contraction in the acquisition of capital and consumer goods, which evidences a lower dynamism in investment.
- Macroeconomic outlook for 2025.
As has been pointed out by various economic actors, moderate growth is expected for Mexico, supported by domestic demand and a more favorable external environment. On the supply side, expansion is also expected to be driven by industrial activity-particularly in the construction, power generation and manufacturing sectors-as well as by growth in services, favored by plans to expand the railroad network.
Regarding the main macroeconomic variables, the country's economic growth is expected to be between 0.5% and 1.5% real annual growth. Inflation is expected to maintain its downward trend and close the year at 3.8% annually. The Bank of Mexico's reference interest rate is expected to end the year at 7.25%, that is, 75 basis points below the original forecast. The exchange rate is expected to close at 19.9 pesos per dollar, influenced by persistent trade uncertainty. The balance of payments is projected to show a deficit equivalent to 0.3% of GDP.
These projections are based on the premise of an early resolution of trade tensions, the success of strategic projects such as the Mayan Train and the Interoceanic Corridor, as well as the growth of the U.S. economy.
On the other hand, federal government revenues grew 9.3% between January and July 2025, as a result of salary improvements and a more efficient tax administration. Tax revenues increased 7.2% in real terms, driven by a 7.1% increase in income tax revenues and an 8.3% increase in VAT, among other items. Non-tax revenues increased 20.4%, mainly due to Banco de México's operating surplus.
Budget revenues are expected to reach 21.9% of GDP at year-end, driven in part by the increase in tax revenues, which will reach 14.8% of GDP, with a real annual growth of 3.5% in tax revenues.
Non-tax revenues are expected to reach 1.1% of GDP, which represents 16.8 billion pesos more than budgeted. Oil revenues are expected to reach 2.7% of GDP, 0.1 billion pesos lower than in 2024, due to lower hydrocarbon production.
By the end of 2025, the budget deficit is projected at 3.6% of GDP, a significant reduction from the 4.9% recorded in 2024.
Note: Partial sums may not add up due to rounding.
* Nominal GDP estimated in the General Economic Policy Criteria 2025 is considered.
1/ Includes CFE, IMSS and ISSSTE.
2/ Includes the inflationary component of inflation-indexed debt, income from debt repurchases, as well as an adjustment for income derived from the net sale of financial assets and from the net acquisition of liabilities other than debt and the balance sheet of indirectly controlled entities.
Source: SHCP.
II. GENERAL ECONOMIC POLICY CRITERIA
The revenue policy, as stated by the Executive Branch, will be aimed at strengthening collection efficiency. Likewise, in 2026, the tax base will be broadened through a series of provisions aimed at safeguarding the physical and mental health of the population, while incorporating measures to support various sectors in order to boost the country's economic development.
For fiscal year 2026, revenues are budgeted at Ps. 8,721.1 billion, Ps. 519.2 billion higher than the estimated closing of 2025, which represents a real increase of 6.3%. Mostly due to a 5.7% real increase over the estimated closing of 2025 in tax revenues, which represent 314.4 billion pesos over the estimated closing of 2025.
- Tax Revenues.
Total tax revenues in 2026 are expected to reach 5,838.6 billion pesos and show a real growth of 5.7% with respect to the estimated closing of 2025.
Revenue growth is mainly explained by an increase in the import component of 40.7% real, which represents 23.44% of the estimated increase in tax revenues, although increases of 2.5% and 3.6% real annual increase in income tax and VAT, respectively, which represent 23.76% and 17.62%, respectively, of the estimated increase in tax revenues, will also have an impact.
- Public spending policy.
Priority will be given to projects with high social and economic impact, with emphasis on historically lagging regions and strategic sectors for the country's development.
III. FEDERAL REVENUE LAW.
Surcharges.
- It also seeks to increase the surcharge rates applicable to the payment of unpaid tax credits from 0.98% to 1.38% per month.
- In the case of loans paid in installments, the following increases are proposed:
- The late payment surcharge rate increases from 1.26% per month to 1.38% per month.
IV. FISCAL STIMULUS TO INDIVIDUALS AND CORPORATIONS.
- Tax regularization program.
It is proposed to continue the tax regularization program aimed at individuals and corporations, with the purpose of facilitating the payment of debts owed by them with final or consented tax credits, whose administration and collection corresponds to the Tax Administration Service or the National Customs Agency of Mexico, and to encourage voluntary compliance with their tax obligations.
In order to broaden the base of taxpayers eligible for the application of the tax regularization incentive, with respect to the taxpayers' income limit, it is proposed that only the 2024 tax year be considered and that total income not exceed 300 million pesos, which is currently limited to taxpayers whose total income has not exceeded 35 million pesos.
If the initiative is successful, those individuals and companies that have received any remission, reduction, reduction or any other similar benefit in the amount of the payment of tax credits, as well as those that have been benefited by the fiscal stimulus of the same nature of the Federal Revenue Law for the Fiscal Year 2025, are exempted from this benefit.
V. RETURN OF CAPITAL FROM ABROAD.
The 2026 Economic Package proposes, through a transitory provision of the initiative of the Federal Income Law (LIF), a tax benefit for individuals and corporations to repatriate funds of legal origin that are abroad before September 8, 2025.
- Preferential Rate: The capital to be returned will pay a preferential Income Tax (ISR) rate of 15%, without any deduction or the application of the figure of compensation.
- Conditions: To access this benefit, the resources must be invested in Mexico for a minimum period of three years from the date on which the investment is made.
- Valid Investments: Valid investments are considered to be the acquisition of new fixed assets, land and buildings for productive activities in the country, linked to Plan Mexico or the Development Poles. Likewise, investment in research, training, innovation, technological development, payment of liabilities to the Federation, as well as wages and salaries derived from subordinate personal services.
- Exclusions: Those who have a criminal tax record, are published in the lists referred to in articles 69-B (definitive taxpayer who has been issuing invoices for non-existent or non-located transactions and taxpayers who have given any tax effect to invoices issued by definitive taxpayers who have been issuing invoices for non-existent or non-located transactions), 69-Bis (taxpayers who unduly transferred the right to reduce tax losses), of the Federal Tax Code or whose funds come from illicit activities or high risk jurisdictions, are not eligible for this benefit.
The benefit would be in effect during the 2026 fiscal year, allowing the resources returned during the first half of 2026 to be invested no later than December 31, 2026, and those repatriated during the second half of 2026 to be invested no later than June 30, 2027.
VI. KEY TAX CHANGES.
Tax reform initiatives applicable to institutions comprising the financial system.
- Crowdfunding institutions.
It is proposed that crowdfunding institutions comply with the obligation to withhold and pay income tax and VAT on transactions in which they participate as intermediaries.
- Withhold and pay income tax at the rate of 20% on the amount of nominal interest paid to the individuals and entities that contributed the funds for the financing transactions.
- When the interest is paid to foreign residents, the 35% rate will be applied (maximum rate to be applied on the excess of the lower limit established in Article 152 of the Income Tax Law).
- Withhold and pay the value added tax corresponding to interest payments, substituting the persons who receive the interest payments in the obligation of payment and payment of said tax.
- Issue tax receipts to persons from whom income tax and value added tax is withheld, indicating the amount of interest paid and withholdings made, no later than 5 days following the month in which the withholding was made.
- Collective financing institutions must provide information regarding interest paid in the immediately preceding calendar year, in accordance with the following:
- Submit to the Tax Administration Service, no later than February 15 of each year, information on the name, Federal Taxpayer Registry, domicile of the taxpayer in question and the nominal and real interest, the average nominal interest rate and number of days of the investment.
- Provide to the persons to whom the payments are made, no later than February 15 of each year, proof of the nominal and real interest or, as the case may be, the loss determined and the withholdings made.
- Provide monthly, no later than the 17th day of the immediately following month, information on cash deposits exceeding $15,000.00.
Investors, whether individuals or corporations, who contribute funds to a crowdfunding institution for the purpose of providing financing to applicants would receive a lower net return than in previous years.
- Interest withheld by the institutions comprising the financial system.
It is proposed that the institutions that make up the financial system that make interest payments must withhold and pay the tax by applying the fixed withholding rate of 0.90 percent applicable to the amount of the principal that gives rise to the payment of interest. The current rate is 0.50 percent calculated on the same basis and calculation methodology.
- Multiple banking institutions and credit institutions.
The Bank Savings Protection Law established the obligation of multiple banking institutions to pay a fee to the IPAB, either ordinary and extraordinary fees established by the Board of Governors, in order to establish a system for the protection of bank savings (which is indispensable for multiple banking institutions, since failure to pay them could result in the dissolution of the institution), However, since the Executive considers that these fees are not strictly indispensable, i.e., they do not correspond to expenditures for the generation of income of commercial banks, three quarters of the fees paid to the IPAB by commercial banks will not be deductible, in order to avoid abuses in the deduction of expenditures that reduce the income tax base.
Since the IPAB's Board of Directors establishes different ordinary fees for the Institutions, depending on the risk to which they are exposed, based on the level of capitalization of each one of them and according to other general indicators, the fiscal impact of this initiative is not proportional, which is why this initiative is contrary to said tax principle.
Also, since the tax authorities, in the exercise of their verification powers, have detected abuses of the bad debt deduction applicable to credit institutions, it is proposed to standardize the treatment of the bad debt deduction with the rest of the taxpayers, eliminating the special treatment established in the third and fourth paragraphs of section XV of article 27 of the Income Tax Law, the current text of which is transcribed below:
"In the case of Credit Institutions, it is considered that there is a notorious practical impossibility of collection in the loan portfolio when such portfolio is written off in accordance with the provisions established by the National Banking and Securities Commission.
The provisions of the preceding paragraph shall be applicable provided that, in the exercise of verification powers, they provide the tax authorities with the same information supplied in the primary database controlled by the credit information companies referred to in the Law to Regulate Credit Information Companies."
- Financial intermediaries.
The institutions that make up the financial system that intervene as intermediaries in securities lending transactions, for which it is not considered that there is alienation of assets, in substitution of the current withholding rate of 0.50 percent (for 2025) applicable on the amount of the principal that gives rise to the payment of interest (See Withholding of interest by the institutions that make up the financial system), will withhold and pay the tax at the rate of 9 percent on the amount of nominal interest defined as agreed premium.
- Investment funds.
Investment funds must pay monthly, no later than the 17th day of the month following the month in which the taxable interest is accrued in favor of the shareholders of the funds and the tax that corresponds to its members or shareholders is calculated on the amount of the capital that gives rise to the payment of interest considering the withholding rate of the current rate of 0.50 percent (for 2025) (See Withholding of interest by the institutions that make up the financial system).
However, the Executive's proposal states that investment funds in debt instruments and variable income investment funds that carry out securities lending transactions, for which it is not considered that there is a disposal of assets, will exclude from the calculation of the daily tax the interest defined as agreed premium. Investment funds must withhold the tax corresponding to their members or shareholders for such interest at the rate of 9 percent on the amount of the nominal interest defined as agreed premium.
- Foreign legal entities that manage private equity investments.
Some of the requirements for foreign private equity funds to be considered as fiscally transparent are made more flexible in order to promote greater investment in the country by this type of funds.
The administrator of the foreign legal entity may be a tax resident in Mexico, while the foreign legal entity retains fiscal transparency.
Specialized investment companies of retirement funds, which are members or members of foreign legal entities, may not apply the treatment of accumulating income obtained by members or members residing in Mexico or permanent establishments of residents abroad, even if the members or members had been exempt from tax with respect to such income in the proportion that corresponds to them due to their participation in them, with the foreign legal entity maintaining fiscal transparency.
In the current text of the Income Tax Law, by not accruing income in accordance with Articles 4B or 177 of the Income Tax Law, the foreign legal entity will not enjoy tax transparency in the proportion of the participation of the member or member whose income was not accrued.
VII. EXCISE TAX ON PRODUCTION AND SERVICES (IEPS).
The IEPS reform proposals seek to increase revenue in sectors sensitive to public health and entertainment.
- Tobacco and Nicotine: A significant increase in taxes on these products is sought.
1. The tax for tobacco products will be increased from 160% to 200%.
2. The specific fee per cigar will rise from $0.8516 in FY 2026 to $1.1584 on a staggered basis through 2030, as shown below:
New products containing nicotine, such as bags, pouches and non-prohibited vape devices, will be taxed at 200% according to the proportional content in milligrams of nicotine.
4. Replacement therapies with sanitary registration will be exempt from the tax.
- Flavored beverages: The objective is that the total tax burden of these beverages exceeds 22% of the retail price.
1. The specific fee per liter will increase from $1.6451 to $3.0818, which represents an 87% increase.
2. The levy will now also apply to beverages with natural or artificial sweeteners, including light, zero or diet versions.
- Gaming and Sweepstakes: An increase in the tax rate is proposed.
1. The rate for face-to-face and online gaming will go up from 30% to 50%.
2. New obligations will be established for foreign suppliers, and non-compliance could result in the digital blocking of their services.
- Video games: A new IEPS of 8% will be created on the sale or download of video games with violent or adult content, that is, those video games classified as category C and D, because they are considered unsuitable for minors under 18 years of age due to their violent, extreme or adult content, among others, according to the classification of the Mexican System of Equivalences of Video Game Classification, both in physical format and in the services that allow access to or download of such video games in Mexican territory.
1. Digital platforms must register in the RFC, designate a legal representative and tax domicile in Mexico, as well as withhold 100% of this tax.
2. The initiative warns that the definition of violent video games is ambiguous, since this classification determines the age or age group at which the use of a video game is recommended, which could lead taxpayers to challenge the tax by means of an amparo for unconstitutionality, since it is a classification based on the recommendation of the Mexican System of Equivalences of Classification of Video Games, and which restricts freedoms, especially of adults with full legal faculties.
VIII. DIGITAL PLATFORMS.
The reforms seek to strengthen fiscal control over the digital economy, imposing greater obligations on platforms.
- Income tax and VAT withholdings: New withholding rules will be implemented.
1. Income tax: Withholdings will be uniform: 2.5% for individuals and 4% for corporations that obtain income from the sale of goods and services rendered through technological platforms, computer applications and similar. The tax withheld may be credited against provisional payments or in the annual tax return.
VAT: The withholding obligation extends to national and foreign digital intermediation platforms in the following cases:
- To legal entities on the same terms as for individuals, i.e., 50% or 100% of the VAT, depending on whether the RFC is provided.
- To residents abroad without a permanent establishment who sell goods in national territory, 100%.
- To the suppliers of goods and services in national territory when payments are deposited in bank accounts or deposit accounts abroad, 100%.
IX. FEDERAL TAX CODE.
- Federal Taxpayers Registry (R.F.C.).
It is proposed that the Tax Authority may deny the registration in the R.F.C. to legal entities whose partners, shareholders, associates, representatives and/or any other member of their organizational structure, participate in companies that are located within the following assumptions:
I. Be considered as Companies that Invoice Simulated Operations (EFOS).
II. Are classified as Companies that Deduct Simulated Operations (EDOS).
III. The use of the Digital Seal Certificates (CSD) has been restricted without having denied the reason for which such measure was imposed.
IV. Have firm tax credits.
V. Are found as unlocated.
VI. Have a conviction for the commission of a crime.
- Restriction of Digital Seal Certificates.
New assumptions for the temporary restriction of stamps for the issuance of Digital Tax Receipts issued through the Internet (CFDI), among which are:
I. Failure to provide information on customs matters.
II. To have unpaid tax credits, when having issued CFDI'S in the immediately preceding fiscal year, for amounts greater than four times the historical amount of the credit.
III. To issue CFDI's without the key of the income.
IV. Omitting to declare the permit number issued by the National Energy Commission (CNE), or declaring an incorrect one.
V. To dispose of fuels without having imported or acquired them in accordance with the applicable provisions.
VI. To have given fiscal effects to "false" CFDI'S, that is to say, that cover nonexistent operations.
- Digital Tax Receipts via Internet (CFDI'S).
It is proposed to add a paragraph g) to Section V of Article 42, to establish the obligation that the CFDI'S must cover existing transactions, compliance with which will be subject to the review powers contained in said article.
- Requirements of the CFDI'S.
1. For the issuance of CFDI'S for the distribution or sale of hydrocarbons, the number of the permit issued by the CNE for the distribution or sale of hydrocarbons or petroleum products must be added.
2. The possibility of canceling the CFDI's no later than the month in which the annual income tax return corresponding to the fiscal year in which they were issued must be filed, as long as the recipient accepts the cancellation.
- Powers of Verification.
Power of verification of CFDI'S, with the issuance of Article 49 BIS, directly related to the proposed addition of paragraph g), section V of Article 42, which contemplates the following procedure:
I. Issuance of a home visit order, in which the reasons for which the tax authority considers that the CFDI'S issued are false, simultaneously ordering the suspension of the Certificate of Digital Stamps (CSD), in order to avoid the issuance of CFDI'S during the development of such visit.
II. For the notification procedure of the visit order, the tax authority may initiate the taking of photographs, audio or video recordings.
III. Once the procedure has been initiated, a detailed report will be drawn up detailing the facts observed, as well as the possible irregularities that have been detected, to be refuted by the visited party, in the same proceeding, or within five working days after the proceeding has been carried out, by means of the corresponding evidence.
IV. Once the period indicated in the immediately preceding paragraph has elapsed, the tax authority will have a period of 15 days to issue and notify the respective resolution, which may:
1. To indicate that the reviewed taxpayer has disproved the irregularities observed and, as a consequence, the CSD restriction will be lifted, or
2. To indicate that the reviewed taxpayer did not correct the irregularities observed, which will imply that the CFDI's issued will be considered as "false", and therefore will not be able to have fiscal effects.
V. In the event that the assumption contained in numeral 2 of the previous section is met, the data of those taxpayers that fall within the assumption in question will be published both on the tax authority's website and in the Official Gazette of the Federation, so that those third party recipients of the CFDI'S involved may proceed to reverse the tax effects previously granted to such taxpayers. Otherwise, the tax authority could temporarily restrict the use of their CSD.
VI. As a result of this review, the tax authority will be empowered to bring criminal action against taxpayers who fail to rebut the presumption of falsity of the CFDI's.
VII. The development of the aforementioned visit must be concluded no later than 24 days after its commencement.
- Finally, in an obscure and incongruent wording, it is proposed that the summons proceeding in which the tax authorities inform the taxpayer of the facts or omissions in the audit carried out, be made after the notification of the last partial assessment, of the official notice of observations or of the provisional resolution, as applicable, which is currently made prior to such notification.
- Real-time monitoring.
The reform initiative considers adding article 30-B, with the obligation of digital service providers (articles 1-A BIS and 18-B of the VAT Law) to allow the tax authority access, in real time, to the information contained in their systems or records related to the operations of the services they provide, under penalty of temporarily blocking access to the digital service in question.
- Guarantee of the fiscal interest.
It is proposed to amend Article 141 of the CFF, to establish a mandatory order of priority of the options to guarantee the tax interest, and to read as follows:
I. Deposit bill (addendum, which covers a cash deposit, and which is issued exclusively by Banco del Bienestar S.N.C.).
II. Letter of Credit (added).
III. Pledge or mortgage.
IV. Bail.
V. Joint and several obligation of a third party.
VI. Garnishment in administrative proceedings.
If the tax credit cannot be fully secured with the previous option, the difference may be secured with the subsequent option, according to the proposed order.
- Appeal for Revocation.
The prerogative to stop guaranteeing the credit with the sole filing of the appeal for revocation is eliminated, eliminating from the second paragraph of article 144 said appeal, to only recognize the appeal of nonconformity and, therefore, not being obligated to exhibit the guarantee. The foregoing obliges the taxpayer to offer a guarantee when the appeal for revocation is filed in order for the tax authority to grant the suspension.
- Public officers.
Public notaries are required to declare, under oath, the authenticity of the documents presented by taxpayers before the tax authority, when required to do so by the tax authority.
The 2026 tax reform initiative in Mexico will follow the legislative process foreseen in the Constitution, being on September 22 when the Finance and Public Credit Commission (Federal Income Law, Federal Law of Rights, Law of the Special Tax on Production and Services and the one corresponding to the Fiscal Code of the Federation) and the Budget and Public Account Commission (the Draft Budget of Expenditures of the Federation and the Proposal for the Declaration of the 2026 Priority Attention Zones, the latter also to the Welfare Commission for opinion), both of the Chamber of Deputies, could begin to meet, for their analysis, discussion and opinion, before being debated and voted in the Plenary. If approved, it will pass to the Senate of the Republic for its review, where it may be modified, approved or rejected, with a deadline of October 31 to approve the Federal Income Law. If both chambers agree on the final text, it will be sent to the President of the Republic for its promulgation and publication in the Official Gazette of the Federation, entering into effect, in general, on January 1, 2026, as well as the date established by the decree itself for specific issues.