Decree granting tax incentives to support the national strategy "Plan Mexico" for new investments, dual training, and innovation

DOF: 21/01/2025

DECREE granting tax incentives to support the national strategy named "Plan Mexico", to foster new investments, incentivize dual training programs, and drive innovation.

At the margin, a seal with the National Coat of Arms, which reads: United Mexican States.- Presidency of the Republic.

CLAUDIA SHEINBAUM PARDO, President of the United Mexican States, in exercise of the authority conferred upon me by Article 89, Section I, of the Political Constitution of the United Mexican States, based on Articles 31 and 34 of the Organic Law of the Federal Public Administration and Article 39, first paragraph, Section III, of the Federal Tax Code, and

CONSIDERING

That, on November 27, 2024, as part of the national strategy named "Plan Mexico", the Head of the Federal Executive presented to the Advisory Council for Regional Economic Development and Relocation (1), whose main task is to promote and implement the National Relocation Strategy, as well as private sector actions to concretize investments, generate jobs, and promote regional development;

That the Advisory Council for Regional Economic Development and Relocation, within its actions, contemplates promoting projects through mixed investment and infrastructure schemes, to strengthen industrial corridors and Welfare Poles; develop local/regional supply chains; increase investment and export amounts; double dual education programs, certifications, and technical careers, among others;

That, on January 13, 2025, the President of the Republic presented the national strategy named "Plan Mexico" (2), which establishes, among other goals: strengthen national industry for the local/regional market; expand import substitution with value chains; generate jobs; strengthen scientific, technological development and innovation; position Mexico among the ten largest economies worldwide, in order to achieve well-being for all Mexicans;

That, in order to maximize the competitive advantages of our country, develop local/regional supply chains, and strengthen training and technological innovation, as well as direct marketing channels, the Head of the Federal Executive considers it necessary to make more efficient the incentives currently granted to foreign companies relocating in the national territory and to promote those national companies that have the capacity to integrate into value chains; therefore, through this instrument, tax incentives are granted without distinction of industrial sectors or of national or foreign companies, considering the participation of micro, small, and medium-sized enterprises (MSMEs);

That, in addition to allowing access to the largest possible number of companies, it is important to provide security to investors, favor liquidity, generate greater investment and economic development, so this Government considers it appropriate that the tax incentives be applicable until September 30, 2030;

That it is fundamental to foster the development of technical capacities, mainly through the programs of the Dual Education System under the responsibility of the Secretariat of Public Education (SEP), to have a highly qualified industry in technical and technological terms. The implementation of the dual education model in the National Education System has allowed the development of qualified labor capable of responding to the current demand of the productive sector, which makes it possible to create a collaboration network between educational institutions and the business sector for the training and education of students/apprentices;

That the Government of Mexico, with the intention of taking full advantage of this educational model and in congruence with "Plan Mexico", considers it necessary to subject the additional deduction for training expenses to the requirement that companies have a collaboration agreement signed with the SEP for the implementation of dual education;

That, within the objectives of "Plan Mexico", is also the promotion of national innovation, through support for investment projects that promote the development of inventions for the obtaining of patents, or initial certifications that enable taxpayers to integrate into local/regional supply chains; therefore, the Head of the Federal Executive deems it convenient to grant a tax incentive consisting of an additional deduction for expenses associated with these items;

That, by allowing tax incentives to be applied by a larger number of companies, it is necessary to establish evaluation and control measures to provide transparency and certainty, so this Government considers it necessary to create an Evaluation Committee integrated by representatives of the Secretariat of Finance and Public Credit and the Secretariat of Economy with the participation of the Advisory Council for Regional Economic Development and Relocation;

That the committee will evaluate investment projects in new fixed assets, collaboration agreements on dual education, or investment projects that lead to the development of inventions for the obtaining of patents or for initial certification that allows companies to join local/regional supply chains, presented by those companies intending to apply the tax incentives, and, if applicable, will issue the certificate of compliance, which will allow applying the tax incentives established in the decree. This, in accordance with the guidelines issued by said committee;

That, as a budgetary control measure in the application of tax incentives, the total amount that the Evaluation Committee will authorize to companies will not exceed 30 billion pesos during the validity of this decree, of which 28 billion 500 million pesos will be allocated for the tax incentive on investment in new fixed assets and the remaining 1 billion 500 million pesos for the tax incentive on the additional deduction for training and innovation expenses;

That another control measure will consist of the Evaluation Committee determining for each fiscal year the maximum amount of tax incentives that taxpayers may apply, in accordance with the guidelines referred to in this instrument;

That, with the purpose of promoting tax incentives among MSMEs, this administration considers it appropriate to establish in this decree that, of the total amount of incentives, at least 1 billion pesos will be allocated to taxpayers with total income in the immediate previous fiscal year of up to 100 million pesos, and

That, in exercise of the authority established in Article 39, first paragraph, Section III, of the Federal Tax Code, I have deemed it appropriate to issue the following

DECREE

Article First. A tax incentive is granted to legal entities that pay taxes under the terms of Titles II or VII, Chapter XII, of the Income Tax Law, and to natural persons who pay taxes in accordance with Title IV, Chapter II, Section I of said law, provided that they meet, among others, the following requirements:

I.

Be registered in the Federal Taxpayer Registry and have the tax mailbox enabled under Article 17-K of the Federal Tax Code;

II.

Have a positive opinion on the compliance with tax obligations referred to in Article 32-D of the Federal Tax Code;

III.

Present the investment project; the collaboration agreement signed with the Secretariat of Public Education on dual education; the investment project for the development of the invention or for initial certification, as applicable;

IV.

Have the certificate of compliance issued by the Evaluation Committee to apply the tax incentives of this instrument, and

V.

Comply with the guidelines issued by the Evaluation Committee for this purpose.

The incentive consists of opting to make the immediate deduction of the investment in new fixed assets, acquired from the date of entry into force of this decree until September 30, 2030, deducting in the fiscal year in which the investment is made the amount resulting from applying to the original amount of the investment, only the percentages established in Article Second of this decree, instead of those indicated in Articles 34, 35, and 209, sections B and C of the Income Tax Law, as applicable.

The portion of said amount that exceeds the amount resulting from applying the percentage established in Article Second of this decree, will be deductible only under the terms of Article Third, first paragraph, Section III, of this decree.

The provisions of this article will only be applicable with respect to those investments that taxpayers maintain in use for a minimum period of two immediate fiscal years following the year in which their immediate deduction is made, except in the cases referred to in Article 37 of the Income Tax Law.

The provisions of this article are not applicable regarding office furniture and equipment, automobiles propelled by internal combustion engines, automobile armor equipment, or any unidentifiable individual fixed asset, nor regarding aircraft other than those dedicated to agricultural aerial fumigation.

For the purposes of this article, new goods are considered those used for the first time in Mexico.

For the purposes of Article 14, Section I, of the Income Tax Law, taxpayers who in the fiscal years 2025, 2026, 2027, 2028, 2029, or 2030 apply the immediate deduction of investment in new fixed assets established in this decree, must calculate the profit coefficient of provisional payments made during the fiscal year of 2026, 2027, 2028, 2029, 2030, or 2031, adding the fiscal profit or reducing the fiscal loss of the year 2025, 2026, 2027, 2028, 2029, or 2030, as applicable, with the amount of the deduction referred to in this article.

The fiscal profit determined under the terms of Article 14, Section II, of the Income Tax Law, may be reduced by the amount of the immediate deduction made in the same fiscal year under the terms of this article. The cited amount of the immediate deduction must be reduced in equal parts in the provisional payments corresponding to the fiscal year in question, starting from the month in which the investment is made. This reduction must be made in the provisional payments of the year in an accumulative manner. For the purposes of this paragraph, the profit coefficient determined under the terms of Article 14, Section I, of the Income Tax Law, cannot be recalculated.

Taxpayers must keep a specific record of the investments for which they opted to apply the immediate deduction under the terms of this article, which contains the supporting documentation, describes the type of good, the relationship with their main business or activity, the specific process or activity in which the good was used, the percentage for deduction purposes applicable to it, the year in which the deduction was applied, and the date on which the good is sold, lost due to fortuitous event or force majeure, or ceases to be useful.

For the purposes of Article 5 of the Value Added Tax Law, the immediate deduction established in this decree is considered as a fully deductible expenditure, provided that the requirements established in the Income Tax Law are met.

Article Second. The percentages that may be applied to deduct the investments referred to in the previous article are as follows:

% Deduction

2025-2026

2027-2030

I. Fixed assets by type of good:

a)

Regarding constructions:

1.

For properties declared as archaeological, artistic, historical, or heritage monuments, in accordance with the Federal Law on Archaeological, Artistic, and Historical Monuments and Zones, which have the restoration certificate issued by the National Institute of Anthropology and History or the National Institute of Fine Arts.

72%

67%

2.

In other cases, including installations, additions, repairs, improvements, adaptations, as well as any other construction carried out on a mining lot in accordance with Article 12 of the Mining Law.

56%

49%

b)

Regarding railways:

1.

For fuel supply pumps for trains.

41%

35%

2.

For railway tracks.

56%

49%

3.

For railway cars, locomotives, couplers, and auto-couplers.

60%

54%

4.

For track leveling machinery, spike pullers, track grinders, motor jacks for lifting the track, remover, inserter, and sleeper drilling machine.

64%

58%

5.

For communication, signaling, and remote control equipment.

72%

67%

c)

For vessels.

60%

54%

d)

Regarding aircraft:

1.

For those dedicated to agricultural aerial fumigation.

86%

83%

e)

For automobiles whose propulsion is through rechargeable electric batteries, electric motor that also have an internal combustion engine or an engine powered by hydrogen, buses, cargo trucks, tractor-trailers, forklifts, and trailers.

86%

83%

f)

For desktop and laptop personal computers; servers; printers, optical readers, plotters, barcode readers, scanners, external storage units, and computer network concentrators.

88%

85%

g)

For dice, dies, molds, matrices, and tooling.

89%

86%

h)

Regarding telephone communications:

1.

For transmission towers and cables, except fiber optic cables.

56%

49%

2.

For radio systems, including transmission and handling equipment that uses the radio spectrum, such as digital or analog microwave radiotransmission, microwave towers, and waveguides.

67%

62%

3.

For equipment used in transmission, such as internal plant circuits that are not part of switching and whose functions are focused towards trunks arriving at the telephone central, including multiplexers, concentrator equipment, and routers.

72%

67%

4.

For telephone central equipment destined for switching calls of technology other than electromechanical.

86%

83%

5.

For others.

72%

67%

i)

Regarding satellite communications:

1.

For the satellite segment in space, including the main body of the satellite, transponders, antennas for transmission and reception of digital and analog communications, and monitoring equipment on the satellite.

67%

62%

2.

For ground satellite equipment, including antennas for transmission and reception of digital and analog communications and equipment for satellite monitoring.

72%

67%

j)

For conventional bicycles, bicycles, and motorcycles whose propulsion is through rechargeable electric batteries.

86%

83%

% Deduction

2025-2026

2027-2030

II. For machinery and equipment other than those indicated in the previous section, the following percentages must be applied, according to the activity in which they are used:

a)

In the generation, transmission, transformation, and distribution of electricity; in grain milling; in sugar and its derivatives production; in the manufacture of edible oils; in maritime, riverine, and lacustrine transport.

56%

49%

b)

In the production of metal obtained in the first process; in the manufacture of tobacco products and natural carbon derivatives.

60%

54%

c)

In the manufacture of pulp, paper, and similar products.

64%

58%

d)

In the manufacture of motor vehicles and their parts; in the construction of railways and ships; in the manufacture of metal products, machinery, and professional and scientific instruments; in the preparation of food products and beverages, except grains, sugar, edible oils, and derivatives.

67%

62%

e)

In leather tanning and the manufacture of leather articles; in the preparation of chemical, petrochemical, and pharmacobiological products; in the manufacture of rubber and plastic products; in graphic printing and publishing.

70%

65%

f)

In electric transport; in fixed infrastructure for the transport, storage, and processing of hydrocarbons, on drilling platforms and vessels, and vessels for hydrocarbon processing and storage.

72%

67%

g)

In the manufacture, finishing, dyeing, and printing of textile products, as well as clothing garments.

74%

69%

h)

In the mining industry; in the construction of aircraft and in land transport of cargo and passengers. The provisions of this subsection will not be applicable to the machinery and equipment indicated in subsection b) of this section.

76%

71%

i)

In air transport; in the transmission of telegraph services and by radio and television stations.

80%

76%

j)

In restaurants.

83%

80%

k)

In the construction industry; in agriculture, livestock, forestry, and fishing activities.

86%

83%

l)

For those intended directly for the research of new products or technology development in the country.

89%

86%

m)

In the manufacture, assembly, and transformation of magnetic components for hard drives and electronic cards for the computer industry.

91%

89%

n)

In other activities not specified in this article.

72%

67%

In the case that taxpayers engage in two or more of the activities indicated in this section, the percentage corresponding to the activity in which they obtained the largest part of their income in the fiscal year in which the immediate deduction of the investment is applied must be applied.

Taxpayers will make the immediate deduction established in this decree, only regarding investment in new fixed assets, whose acquisition has as its purpose their exclusive use for the development of their activities.

Article Third. Taxpayers referred to in Article First of this decree, regarding the goods to which they applied it, must adhere to the following:

I.

The original amount of the investment may be adjusted by multiplying it by the corresponding update factor for the period from the month in which the good was acquired until the last month of the first half of the period elapsed from when the investment was made until the close of the fiscal year in question.

The product resulting from the previous paragraph must be considered as the original amount of the investment to which the percentage referred to in the previous article is applied for each type of good.

II.

Gain obtained from the alienation of the goods is considered to be the total income received from the same.

III.

When the goods are sold, lost, or cease to be useful, a deduction may be made for the amount resulting from applying, to the original amount of the investment adjusted with the update factor corresponding to the period from the month in which the good was acquired until the last month of the first half of the period in which the deduction referred to in Article First of this decree was made, the percentages resulting according to the number of years elapsed since the deduction referred to in the cited article was made and the immediate deduction percentage applied to the good in question, as follows:

Taxpayers referred to in Article First of this decree, who make investments in fixed assets by type of good referred to in Article Second, Section I, of this decree, will apply respectively for the years 2025 to 2026 and for the years 2027 to 2030, the following tables:

Taxpayers referred to in Article First of this decree, who make investments in machinery and equipment other than those indicated in Article Second, Section I, of this decree, will apply respectively for the years 2025 to 2026 and for the years 2027 to 2030, the following tables, according to the percentage corresponding to the activities referred to in Section II of the cited Article Second:

For the purposes of this article, when the number of months of the period referred to in Sections I and III of this article is odd, the last month of the first half shall be considered the month immediately preceding the one corresponding to half of the period.

Article Fourth. Taxpayers referred to in Article First of this decree may apply in the annual return of the fiscal years 2025, 2026, 2027, 2028, 2029, and 2030 a tax incentive consisting of an additional deduction equivalent to 25% of the increase in expenses incurred for training received by each of their workers in the fiscal year in question or for expenses incurred for innovation. For these purposes, the increase will be the positive difference between the expenses incurred for training or for innovation in the fiscal year in question and the average expenses that the taxpayer has incurred for the same concepts in the last three fiscal years prior to that in which such expenses were incurred, averaging even when no expenses were incurred in said years for these concepts.

The training referred to in this article will be that which provides technical or scientific knowledge linked to the taxpayer's activity.

The expenses for innovation referred to in this article will be those linked to investment projects for the development of inventions, which allow the obtaining of patents, and those investment projects developed for the obtaining of initial certifications required by taxpayers for their integration into local/regional supply chains, according to what is indicated in the guidelines referred to in Article First of this decree.

For the purposes of the additional deduction for training expenses, it will only be applicable with respect to training provided by taxpayers to their active workers registered with the Mexican Social Security Institute, in accordance with the guidelines referred to in Article First of this decree.

Taxpayers who do not apply the additional deduction established in this article in the fiscal year in which the expense was incurred, will lose the right to do so in subsequent years.

The additional deduction referred to in this article for the relevant fiscal year shall be subtracted from the difference between the taxable income obtained in said year and the authorized deductions in accordance with the Income Tax Law, up to the amount of said difference. In the event that the authorized deductions in accordance with the Income Tax Law are greater than the taxable income obtained in the fiscal year, no amount shall be reduced by way of the additional deduction referred to in this present article.

The fiscal incentive established in this article shall not be cumulative for the purposes of the Income Tax Law.

Taxpayers must carry out specific registration of the training or of the investment projects for the development of the invention or of initial certification in the terms established by the guidelines referred to in Article First of this decree.

Article Fifth. The Evaluation Committee for the application of the fiscal incentives referred to in this present decree is created. Said committee shall be composed of one representative of the Ministry of Economy, one from the Advisory Council for Regional Economic Development and Relocation, who shall only have voice without the right to vote, and one from the Ministry of Finance and Public Credit, who shall preside over the committee and shall have the casting vote.

The composition, powers, quorum, conduct of sessions, decisions, and other aspects relating to the Evaluation Committee, as well as the procedure, criteria, and eligibility parameters that the investment projects presented by taxpayers interested in obtaining the certificate of compliance referred to in fraction IV of Article First of this decree must meet, shall be established in the guidelines referred to in said Article First.

The total amount of fiscal incentives authorized to the taxpayers referred to in this decree shall be up to 30 billion pesos distributed from the entry into force of this present decree until September 30, 2030; said amount shall not exceed 28 billion 500 million pesos for the fiscal incentive referred to in Article First of this decree, nor 1 billion 500 million pesos for the incentive referred to in Article Fourth of this instrument. Of the total amount of incentives, a minimum of 1 billion pesos shall be applied to taxpayers with total income in the immediately preceding fiscal year of up to 100 million pesos.

The committee shall determine for each fiscal year the maximum amount that taxpayers may apply for each of the fiscal incentives referred to in this decree in accordance with the guidelines referred to in Article First of this present instrument.

Article Sixth. The fiscal incentives provided for in this present decree may not be applied by taxpayers who fall under any of the following circumstances:

I.

They are located in any of the circumstances established in Article 69, second-to-last paragraph, of the Federal Tax Code, and whose name, denomination, or trade name and tax identification key in the Federal Taxpayer Registry are contained in the publication on the internet page of the Tax Administration Service referred to in the last paragraph of said article.

II.

They do not rebut the presumption established in Article 69-B, first paragraph, of the Federal Tax Code and, therefore, are definitively in said situation in terms of the fourth paragraph of said article. Likewise, this provision shall not be applicable to taxpayers who have a partner or shareholder who is in the circumstance of presumption referred to in this fraction. The fiscal incentives provided for in this present decree shall also not be applicable to those taxpayers who had carried out operations with taxpayers referred to in this fraction and had not accredited before the tax authorities that they effectively acquired the goods or received the services that support the corresponding digital fiscal receipts.

III.

The presumption established in Article 69-B Bis of the Federal Tax Code has been applied to them, once the list referred to in said article has been published in the Official Gazette of the Federation and on the internet page of the Tax Administration Service.

IV.

They have firm tax credits, or that when exigible, are not guaranteed or well, that the guarantee proves insufficient.

V.

They do not comply with any of the requirements established in this present decree, including the specific registrations of investments and training and innovation referred to in this decree.

VI.

They are in the process of liquidation.

VII.

They are in the procedure for the temporary restriction of the use of digital seals for the issuance of digital fiscal receipts for the Internet, in accordance with Article 17-H Bis of the Federal Tax Code.

VIII.

They have cancelled the certificates issued by the Tax Administration Service for the issuance of digital fiscal receipts for the Internet, in accordance with Article 17-H of the Federal Tax Code.

IX.

They fail to comply with what is provided in the guidelines referred to in Article First of this decree.

Article Seventh. Taxpayers who have applied the incentives of this present decree and fail to comply with the requirements established therein, must pay the tax, update, and corresponding surcharges, in accordance with the legal provisions that apply, and the fiscal incentives must be rendered null and void.

Article Eighth. The Tax Administration Service may issue the rules of a general nature necessary for the due and correct application of this decree.

TRANSITORY CLAUSES

FIRST. This present decree shall enter into force the day following its publication in the Official Gazette of the Federation.

SECOND. From the entry into force of this present decree, the "Decree Granting Fiscal Incentives to Key Sectors of the Export Industry, Consisting in the Immediate Deduction of Investment in New Fixed Asset Goods and the Additional Deduction of Training Expenses," published in the Official Gazette of the Federation on October 11, 2023, and its subsequent modification published in the same official dissemination organ on December 24, 2024, as well as administrative provisions that contravene or oppose what is provided in this present decree, are rendered null and void.

THIRD. Taxpayers who have acquired new fixed asset goods, as well as those who have incurred expenses for training prior to the entry into force of this present decree, who are applying the provisions of the "Decree Granting Fiscal Incentives to Key Sectors of the Export Industry, Consisting in the Immediate Deduction of Investment in New Fixed Asset Goods and the Additional Deduction of Training Expenses," published in the Official Gazette of the Federation on October 11, 2023, and its subsequent modification published in the same official dissemination organ on December 24, 2024, shall continue to apply them until their total conclusion.

FOURTH. The Evaluation Committee shall issue and publish in the Official Gazette of the Federation the guidelines referred to in Article First of this decree, within a period not exceeding 60 natural days counted from the publication of this present instrument in said official dissemination organ.

Given at the residence of the Federal Executive Power, in Mexico City on January 20, 2025.-

President of the United Mexican States, Claudia Sheinbaum Pardo.- Signature.- Minister of Finance and Public Credit, Rogelio Eduardo Ramírez de la O.- Signature.- Minister of Economy, Marcelo Luis Ebrard Casaubon.- Signature.

1

https://www.gob.mx/presidencia/prensa/presidenta-claudia-sheinbaum-presenta-consejo-asesor-de-desarrollo-economico-regional-y-relocalizacion-caderr-como-parte-del-plan-mexico

2

https://www.gob.mx/presidencia/prensa/presidenta-claudia-sheinbaum-presenta-el-plan-mexico-que-contempla-un-portafolio-de-inversiones-de-277-mmdd

https://www.planmexico.gob.mx/

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