Regulatory Alerts2025-10-22 | DOF 5770578Added
Fifth Resolution of Modifications to the General Fiscal Resolution for 2025
The Tax Administration Service amends numerous rules in the General Fiscal Resolution for 2025 to incorporate definitions for hydrocarbon and economic development decrees, update procedures for tax refunds and digital certificates, and expand the scope of entities subject to volumetric controls for hydrocarbons. The resolution adds new acronyms and definitions to the Glossary, modifies conditions for collective tax consultations, and establishes specific requirements for the cancellation of tax registry numbers due to death. It also details the guarantee requirements for CFDI certification providers and updates rules regarding the payment of tax credits and the use of digital signatures.
DOF: 22/10/2025
FIFTH Resolution of modifications to the General Fiscal Resolution for 2025
A seal with the National Coat of Arms appears on the margin, which reads: United Mexican States.- Treasury.- Ministry of Finance and Public Credit.- Tax Administration Service.
FIFTH RESOLUTION OF MODIFICATIONS TO THE GENERAL FISCAL RESOLUTION FOR 2025
AND ANNEXES 1, 1-A, 14, 15, 26, 27, 29, 30, 31 AND 32
The Tax Administration Service, based on articles 16 and 31 of the Organic Law of the Federal Public Administration; 33, fraction I, subsection g) of the Federal Tax Code; 14, fraction III of the Law of the Tax Administration Service and 8 of the Internal Regulations of the Tax Administration Service, resolves:
FIRST.
Rules 1.9., fraction XXV; 2.1.36., fourth paragraph, fraction IV; 2.1.38.,
fraction
II; 2.1.39., first paragraph, fraction II; 2.1.40., second paragraph, fraction XI; 2.1.45., second paragraph, fraction
XII; 2.2.1., twelfth paragraph; 2.2.14., third paragraph; 2.3.2., second and fourth paragraphs; 2.3.14., fifth
paragraph; 2.4.10., third paragraph; 2.5.3.; 2.6.1.2.; 2.6.1.4., first paragraph, fraction VII; 2.6.1.6.; 2.7.2.6.; 2.7.5.4.,
first paragraph; 2.7.7.2.4.; 2.8.3.1., first paragraph; 2.8.3.7., first paragraph; 2.10.27., fourth paragraph, fraction III;
2.14.9., fraction III; 2.14.14., first paragraph, fractions I, II, III, subsection b), second paragraph of subsection y fifth
paragraph of the rule; 3.3.1.8., first paragraph, fraction VIII; 3.3.1.10., fraction VII; 3.3.1.24., fourth paragraph;
3.9.18., second paragraph; 3.18.5., third and fourth paragraphs; 4.3.11.; 4.5.1., third paragraph, fractions I and II;
5.2.27., first and second paragraphs; 9.1.; 9.22.; 10.5., second paragraph, fraction I; 10.6., second paragraph,
fraction I; 10.9., first and second paragraphs; 10.14.; 10.15., epigraph; 10.17.; 10.19.; 10.20., first paragraph,
fractions II and III; 10.24., second paragraph; 10.25., first and second paragraphs; 10.26.; 10.27.; 10.28.; 10.29.,
first paragraph, fractions I and III; 10.30., first paragraph, fraction I; 10.31., first paragraph; 10.32., first and
second paragraphs, fractions III, first paragraph, IV, VI and X; 11.6.1., fraction II; 11.7.1., first paragraph, section
A, fraction III, subsection g), numeral 1 and 12.1.10., first paragraph; are added to the Glossary, fraction II, the
numerals 69, 70, 71 and 72 and fraction III, numerals 16, 17, 18 and 19; rules 5.2.27., fifth and sixth paragraphs;
10.33.; 11.1.9., third paragraph; 11.15.5.; Chapters 11.17., which comprises rules 11.17.1. to 11.17.4. and
11.18. which comprises rules 11.18.1. to 11.18.4., and the Twenty-Fifth Transitory; and are repealed from the
Glossary, fraction II, the numerals 12 and 39, as well as rules 10.7.; 10.10.; 10.11.; 10.12.; 10.22. and the
Tenth Transitory of the General Fiscal Resolution for 2025, to read as follows:
" Glossary
...
I.
...
II.
ACRONYMS:
-
to 11. ...
Repealed.
-
to 38. ...
Repealed.
- to 68.
...
DEPEBI. Oil Rights for Well-being.
LSH. Hydrocarbon Sector Law.
PODECOBI. Economic Development Poles for Well-being.
PODECIBI. Circular Economy Development Poles for Well-being.
III.
DEFINITIONS:
-
to 15. ...
PODECOBI Decree. Decree granting tax incentives in the Economic Development Poles for Well-being, published in the DOF on May 22, 2025 and its modification published in the DOF on July 31, 2025.
PODECOBI Guidelines. Agreement issuing the Guidelines for the Economic Development Poles for Well-being, published in the DOF on May 22, 2025.
PODECIBI Decree. Decree granting tax benefits in the Circular Economy Development Poles for Well-being, published in the DOF on July 04, 2025.
PODECIBI Guidelines. Agreement issuing the Guidelines to apply the Decree granting tax benefits in the Circular Economy Development Poles for Well-being, published in the DOF on July 21, 2025.
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Annexes of the GFR
1.9.
...
I. to XXIV.
...
XXV.
Annex 27, which indicates the updated rates of the IAEEH.
XXVI. to XXX.
...
CFF 28, 31, 32, 33, 35, 81, 82, LISR 5, 121, 178, RCFF 45, GFR 3.5.8., 3.15.1.
Procedure to be followed to obtain the opinion on compliance with tax obligations
2.1.36.
...
...
...
...
I. to III.
...
IV.
When the taxpayer is making advance payments in terms of
rule 2.1.49. and also that, between the date of request and the first payment, or
between each payment made, no more than sixty natural days have passed.
...
...
...
...
...
CFF 31, 32, 32-B Ter, 32-B Quinquies, 32-D, 65, 66, 66-A, 69, 69-B, 69-B Bis, 141, LISR 82, 86,
GFR 2.1.49., 2.11.5., 3.10.1.12., 5.2.2., 5.2.13., 5.2.15., 5.2.17., 5.2.18., 5.2.19., 5.2.20.,
5.2.21., 5.2.25.
Agreement for the payment of owed credits
2.1.38.
...
I.
...
II.
In the case of omission in the payment of withholdings or withholdings made by
part of the sending dependencies or entities, the ADSC that celebrated the
agreement, will make it known to the respective Internal Control Body, as well
as to the Anti-Corruption and Good Government Secretariat.
CFF 17-A, 21, GFR 2.1.28.
Collection of challenged tax credits
2.1.39.
...
I.
...
II.
If once the tax credits are sent to the SAT or to the federal entities, the
issuing authorities have knowledge of the filing of any defense mechanism that is admitted to proceedings, they must inform it by official letter, specifying the following:
a) to k) ...
The administrative units of the SAT, by official letter, may request from the
issuing authorities, information related to the defense mechanisms, up to
two occasions, so that, within the term of 10 business days, counted from
the day following the date of receipt of the official letter, the issuing authority
provides the corresponding information, as well as the documentary support that
it considers necessary.
In case of not receiving the requested information, the return of the
determining document will proceed, informing the issuing authority that, as long as it
does not remedy the request of the administrative units of the SAT, the tax authority
does not have the necessary elements to continue with the collection of the tax
credit.
When the suspension of the administrative execution procedure is ordered,
a copy of the documentation accrediting the suspension must also be attached
and, in case that such suspension is granted conditional, it must be
specified whether the debtor presented the guarantee. Likewise, it must be specified the
date of issuance of the agreement or interlocutory sentence, as well as the date of
notification to the authority of such acts.
The agreements, resolutions or any act that modifies the procedural status or
puts an end to the defense mechanism filed regarding the tax credits of
which they are concerned, must be informed by the issuing authority to the SAT or to the
federal entities, as appropriate, by official letter, attaching a simple copy
of these, except for the definitive resolution or sentence, in which case a certified copy will be sent.
...
GFR 2.1.1.
Option to present collective consultations on the application of tax
dispositions, through organizations that group taxpayers
2.1.40.
...
...
I. to X.
...
XI.
Those related to the LISH, LSH and their Regulations, as well as any
other regime, disposition, term or fiscal condition applicable to the activities,
subjects and entities referred to by said laws and regulations.
XII. to XVIII.
...
...
...
CFF 5o.-A, 32-B Ter, 32-B Quáter, 32-B Quinquies, 34, 69, 82-A, 82-B, 82-C, 82-D, 84-M,
84-N, LISR 4-A, 4-B, 28, 205
Option to present consultations on the interpretation or application of
tax dispositions
2.1.45.
...
...
I. to XI.
...
XII.
Those related to the LISH, LSH and their Regulations, as well as any
other regime, disposition, term or fiscal condition applicable to the activities,
subjects and entities referred to by said laws and regulations.
XIII. to XXI.
...
...
...
CFF 5o.-A, 14-B, 34, 69, 32-B Ter, 32-B Quáter, 32-B Quinquies, 82-A, 82-B, 82-C, 82-D,
84-M, 84-N, LISR 4-A, 4-B, 28, 205
Probative value of the Password
2.2.1.
...
...
...
...
...
...
...
...
...
...
...
Mexican adult individuals registered in the RFC, may present the
request for generation, update or renewal of the Password through the service
SAT ID, in accordance with the procedure sheet 7/CFF " Request for generation,
update or renewal of the Password for individuals " , contained in Annex
1-A.
...
...
...
CFF 17-D, 17-H, 17-H Bis, 27
Requirements for the request for generation or renewal of the e.firma certificate
2.2.14.
...
...
Mexican adult individuals may request the renewal of their
e.firma certificate when the certificate has lost its validity within the year prior to
the corresponding request, provided that they obtain the renewal authorization through
the SAT ID service, in accordance with the procedure sheet 106/CFF " Request for
renewal of the e.firma Certificate for individuals " contained in Annex 1-A.
...
...
...
...
...
...
...
...
CFF 10, 17-D, 69-B, GFR 2.2.1., 2.2.3.
Balances in favor of ISR for individuals
2.3.2.
...
Individuals who opt to apply the facility indicated in this rule,
in addition to meeting the requirements indicated in the tax dispositions, must:
I.
Present the declaration of the fiscal year immediately preceding the one to which the
present Resolution refers, using the e.firma or portable e.firma when requesting the
refund of the balance in favor, for an amount of $10,001.00 (ten thousand one pesos 00/ 100 M.N.) to $150,000.00 (one hundred fifty thousand pesos 00/100 M.N.).
Likewise, taxpayers may use the Password to present the
declaration of the fiscal year immediately preceding the one to which the present
Resolution refers, when the amount of the balance in favor is equal to or less than $10,000.00
(ten thousand pesos 00/100 M.N.).
II.
Capture or select a preloaded account in the application to present the
annual declaration corresponding to the number of their bank account for
electronic transfers with 18 digits (CLABE), as referred to in rule 2.3.5.,
which must be active and in the name of the taxpayer as the holder of the same, as well as the denomination of the institution part of the financial system to which
that account corresponds, it will be understood that it is the one authorized by the
taxpayer to make the deposit of the respective refund, if applicable.
The result obtained from the declaration that has been entered into the
administrative facility, will be at your disposal by entering the tax mailbox and
in the case of taxpayers not obliged to have such mailbox or who
promoted any defense mechanism in which suspension was granted regarding the use of this as a means of communication, they can
verify the result in the section " Status of your refund " available on the SAT Portal,
selecting Procedures and services / More procedures and services /
Constancies, refunds and notifications / Refunds and Compensations.
When the result obtained does not lead to the total or partial refund of the
declared balance, the taxpayer may remedy the inconsistencies detected
at the time of consulting the result, when the option
" remedy inconsistencies " is enabled, for which, they must have their key in the
RFC, the Password to access the Portal and e.firma certificate or portable e.firma,
generating automatically their refund request via FED.
...
Taxpayers who do not fall under the circumstances to apply the facility indicated in
the present rule or when the result obtained from their request does not lead to the
total refund of the declared balance and have not opted for " remedy inconsistencies "
when consulting the result of the automatic refund, may request the refund of their
balance in favor or of the unauthorized remainder as appropriate, through the FED;
entering the SAT Portal, in Procedures and services / More procedures and services /
Constancies, refunds and notifications / Refunds and compensations, in the
section Request your refund / ISR Refund, enter the tax mailbox or, if you are
covered, through the section " Access by password " , for which, they must have
their key in the RFC, the Password to access the Portal and e.firma certificate or the
portable e.firma to perform their submission.
...
...
...
CFF 17-H, 18, 22, 22-B, 22-C, 69, 69-B, LISR 97, 98, 151, GFR 2.3.5., 2.3.8.
VAT refund in pre-operational period
2.3.14.
...
...
...
...
Taxpayers who have the quality of contractors in accordance with the LSH, who are
in the pre-operational period and who opt for the benefit established in rule
10.20., will be subject to what is stated in said rule.
CFF 22, 22-D, LIVA 5o., GFR 2.3.4., 4.1.6., 10.20.
Fiscal identification card and tax status certificate
2.4.10.
...
...
Likewise, Mexican individuals may register their request through the
SAT ID application https://satid.sat.gob.mx and if approved, within a maximum
period of five days, the tax status certificate or fiscal identification card will be sent via
electronic mail registered in the request or via the SAT Mobile application,
entering with their key in the RFC and Password.
CFF 27
Cancellation in the RFC due to death
2.5.3.
For the purposes of articles 27, sections B, fraction II and C, fractions V and XIII of the CFF,
29, first paragraph, fraction XIII and 30, fraction IX of its Regulations, the tax authority may
cancel the RFC due to the death of the individual, without the need for the respective
notice to be presented, when the information provided by various authorities or third parties,
accredits the death of the taxpayer and, additionally, on the date of their death
is active in the RFC:
I.
Without tax obligations, or,
II.
Taxes in accordance with Title IV, Chapter I of the ISR Law, or in any of the
following regimes or has obtained income from those mentioned below, or in combination with any of these:
a)
RIF, provided that it is not obliged to determine the taxable income for
effects of profit distribution, in accordance with Title IV, Chapter II,
Section II of the ISR Law in force until December 31, 2021, in
relation to what is provided in article Second, fraction IX of the
Transitory Provisions of the Income Tax Law,
published in the DOF on November 12, 2021;
b)
Simplified Trust Regime, provided that it is not obliged to
determine the taxable income for effects of profit distribution, in
terms of article 113-G, last paragraph of the ISR Law;
c)
Income from interest;
d)
Income from dividends.
Likewise, the RFC may be cancelled due to death if there is a notice of suspension of
activities presented prior to the death of the taxpayer, regardless of the regime
under which they taxed in accordance with the ISR Law.
In all cases, there must be no tax credit owed by the taxpayer nor must it be
subject to verification powers by the tax authority.
The taxpayer or their legal representative may formulate clarifications and provide the necessary evidence to
disprove the update of data in the RFC carried out by the authority.
LISR 113-G, LISR 2021 111, CFF 27, RCFF 29, 30
Taxpayers obliged to carry volumetric controls of hydrocarbons and
petroleum products
2.6.1.2.
For the purposes of article 28, fraction I, section B, first paragraph of the CFF, it is understood
as persons who manufacture, produce, process, transport, store, including
storage for own use, distribute or alienate, the hydrocarbons and petroleum products
referred to in rule 2.6.1.1., the following subjects:
I.
Legal entities that extract hydrocarbons under a title of
assignment or a Contract for the Exploration and Extraction of hydrocarbons,
as referred to in article 5, fractions VI, XIV and XX of the LSH.
II.
Individuals or legal entities that treat or refine petroleum or process natural gas and
its condensates or the formulation of petroleum products, in terms of articles
5, fractions XXI, XL and XLIX of the LSH and 3, fraction XL of the Regulations of the Law
of the Hydrocarbon Sector, under a permit from the Ministry of Energy or
the National Energy Commission.
III.
Individuals or legal entities that carry out compression, decompression,
liquefaction or regasification of natural gas, in terms of article 3,
fractions X, XV, XXIX and XLI of the Regulations of the Law of the Hydrocarbon Sector,
under a permit from the National Energy Commission.
IV.
Individuals or legal entities that transport hydrocarbons or petroleum products, in the
terms of article 5, fraction XLVIII of the LSH, under a permit from the
Ministry of Energy or the National Energy Commission, including the
transport for own use.
V.
Individuals or legal entities that store hydrocarbons or petroleum products, in terms of articles 5, fraction II of the LSH and 111 of the Regulations of the Law
of the Hydrocarbon Sector, under a permit from the Ministry of Energy or
the National Energy Commission.
VI.
Individuals or legal entities that store or use for own use or
self-consumption, petroleum products or natural gas derived from their activity, under the
following circumstances:
a)
Under a permit from the National Energy Commission for
dispatch for self-consumption of petroleum products.
b)
That they do not have a permit from the National Energy Commission or from
the Ministry of Energy and that they handle a volume greater than or equal to
75,714 liters monthly per year of petroleum products; or
c)
That they have fixed installations for the receipt of natural gas for
self-consumption and do not have a permit for it, provided that their
annual consumption is greater than 5,000 Gigajoules (GJ).
What is stated in this fraction does not include residential users of natural gas and
liquefied petroleum gas.
VII.
Individuals or legal entities that distribute natural gas or petroleum products, in the
terms of article 5, fraction XVI of the LSH, under a permit from the
National Energy Commission.
VIII.
Individuals or legal entities that alienate natural gas or petroleum products, in the
terms of article 5, fractions XII and XVIII of the LSH under a permit
from the National Energy Commission.
CFF 14, 28, LSH 5, Regulations of the Law of the Hydrocarbon Sector 3, 111, GFR 2.6.1.1.
Requirements to carry volumetric controls of hydrocarbons and petroleum products
2.6.1.4.
...
I. to VI.
...
VII.
Regarding the taxpayers referred to in rule 2.6.1.2., fractions III,
IV, V and VII, provide to the marketers who alienate natural gas or
petroleum products in terms of article 5, fraction XII of the LSH, who are their
clients, the information on the records of the volume of hydrocarbons and petroleum products referred to in Annex 30.
VIII.
...
...
CFF 28, LSH 5, GFR 2.6.1.1., 2.6.1.2., 2.6.1.3., 2.8.1.6.
Audits that determine the type of hydrocarbon or petroleum product in question, the
calorific power of natural gas and the octane rating in the case of gasoline
2.6.1.6.
For the purposes of article 28, fraction I, section B, fourth paragraph of the CFF, the
audits that determine the type of hydrocarbon or petroleum product in question, the calorific
power of natural gas and the octane rating in the case of gasoline, must comply with what is
established in Annex 32 and be issued by a laboratory that has accreditation or
recognition in accordance with the Federal Law on Metrology and Standardization or the
Quality Infrastructure Law to carry out the test and sampling methods established in
Annex 32 and, if applicable, approved by the Ministry of Economy, the Ministry of Energy or the National Energy Commission, to provide the
test service regarding the quality of the same, as appropriate.
CFF 28, Federal Law on Metrology and Standardization, Quality Infrastructure Law,
LSH Transitory Twenty-Third, GFR 2.6.1.1., 2.6.1.2., 2.6.1.4., Technical Guidelines
in Matter of Measurement of Hydrocarbons, NOM-001-SECRE-2010, NOM-016-CRE-2016
On the guarantee to obtain authorization to operate as a CFDI certification provider
2.7.2.6.
For the purposes of article 29 Bis, last paragraph of the CFF and the procedure sheet 112/CFF
" Request to obtain authorization to operate as a CFDI certification provider " ,
contained in Annex 1-A, legal entities that obtain the resolution by which they
are granted the authorization to be PCCFDI, must present the guarantee to which they make
reference in said dispositions, which will guarantee the compliance with the obligations
borne by the aforementioned PCCFDI, consisting of:
I.
Validate that the CSD of the CFDI issuer was valid on the date on which
the receipt was signed and has not been cancelled.
II.
Validate that the key in the RFC of the recipient is in the LRFC.
III.
Send the certified CFDIs to the SAT CFDI reception service, within the
terms and conditions established in fraction IX of rule 2.7.2.8.
The guarantee must cover the entire period for which the authorization was obtained plus six months after the end of its validity. Regarding
the renewal of the authorization, the guarantee must cover twenty-four months,
counted from when the last guarantee exhibited loses its validity.
The acceptance and qualification of the guarantee will be subject to the same meeting the
requirements established in the procedure sheet 112/CFF " Request to obtain authorization
to operate as a CFDI certification provider " , contained in Annex 1-A.
Once the requirements indicated in the cited procedure sheet are met, the ACGSTME
will proceed to notify the PCCFDI of the resolution accepting the guarantee.
When the guarantee does not meet the requirements of the aforementioned procedure sheet, the
ACGSTME will proceed to reject it and will notify the applicant of the causes of said rejection,
granting a term of ten business days counted from the day on which it takes effect the
notification, to remedy the omitted requirements or, if applicable, present a new
guarantee.
In case the provider does not remedy the omitted requirements, does not present a new
guarantee within the granted term, or delivers it after said term has expired, the guarantee will be considered not presented and, consequently, will proceed to its rejection, for which
that the applicant must resubmit their authorization application.
When the ACGSTME detects that the PCCFDI has failed to meet any of the conditions indicated in the preceding subsections and, as a result, the authorization has been revoked under the grounds referred to in rule 2.7.2.12., subsection I, items b) and g), or from the review conducted within six months, counted from the date on which the provider ceased to be an authorized provider, the provider has requested to invalidate their authorization, or has filed notice of the start of the liquidation process, commercial bankruptcy, or has taken an agreement to extinguish the company, it will proceed to evaluate the documents, records, and information that prove the failure to meet the obligations indicated in the preceding subsections and will request the competent authority to enforce the guarantee.
The SAT will return the guarantee when the provider, its liquidators, or the representative of the commercial bankruptcy so request in accordance with procedure form 116/CFF "Request for return of the guarantee presented by the certification provider", contained in Annex 1-A, provided that:
I.
They are not subject to a revocation procedure or there is no pending defense mechanism to be resolved.
II.
Six months have elapsed, counted from the date on which the provider ceased to be an authorized provider, authorization to operate as an authorized provider was requested to be invalidated, or notice of the start of the liquidation process, commercial bankruptcy, or agreement to extinguish the company was filed.
III.
Copies of the certified CFDIs referred to in rule 2.7.2.8., subsection IX are sent.
IV.
The guarantee has not been executed by the SAT.
Certification providers of CFDIs that hold a valid authorization may request the return of a guarantee, provided that it is not the one covering the obligations of the authorization that is currently valid and is not related to a valid guarantee.
CFF 29 Bis, RMF 2.7.2.8., 2.7.2.12.
Issuance of CFDI for withholdings and payment information
2.7.5.4.
For the purposes of articles 13, second paragraph; 76, subsections III, XI, item b) and XVIII; 86, subsection V; 110, subsection VIII; 117, last paragraph; 126, third paragraph; 127, third paragraph; 132, second paragraph; 135; 139, subsection I; 145, paragraphs third and fourth of the Income Tax Law; Second, subsection XVI, third paragraph of the "Decree by which various provisions of the Income Tax Law, the Special Tax on Production and Services Law, the Federal Tax Code, and the Federal Budget and Fiscal Responsibility Law are reformed, added, and derogated", published in the DOF on November 18, 2015, 29, first paragraph and 29-A, second paragraph of the CFF; 32, subsection V and 33, second paragraph of the VAT Law; 5o.-A of the IEPS Law and rule 3.1.14., subsection I, last paragraph, the CFDI for withholdings and payment information shall be issued via the electronic document included in Annex 20. Likewise, the CFDI for withholding may be issued annually in the month of January of the year immediately following that in which the withholding or payment was made, unless there is an express legal or regulatory provision to the contrary, or when the recipient of the CFDI requests it at the time the operation is carried out, regarding those carried out with the persons referred to in the last paragraph of this rule.
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...
...
...
CFF 29, 29-A, LISR 13, 76, 86, 110, 117, 126, 127, 132, 135, 139, 145, 151, 185, LIEPS 5o.-A, LIVA 32, 33, Decree 18/11/15 Second Transitional 2016, RMF 3.1.14., 3.17.7.
Issuance of CFDI with Carta Porte complement in the provision of services for transport or distribution of hydrocarbons or petroleum products at the local level
2.7.7.2.4.
For the purposes of rule 2.6.1.2., regarding subjects that carry out the transport of hydrocarbons or petroleum products by their own means and other than by pipeline, in accordance with article 5, subsection XVI of the LSH or under a permit granted by the National Energy Commission, without the transport involving transit through any section of federal jurisdiction, they must issue a CFDI of type transfer with Carta Porte complement. In the event that the services of transport or distribution of hydrocarbons or petroleum products are contracted, the carrier or distributor must issue a CFDI of type income with Carta Porte complement.
RMF 2.6.1.2., 2.7.7.1.1.
Procedure for filing declarations of provisional or definitive tax payments
2.8.3.1.
For the purposes of articles 20, seventh paragraph, 31, first paragraph of the CFF and 41 of its Regulation, as well as 56 of the LISH, natural and legal persons will file the provisional, definitive, and exercise payments for ISR, IVA, IEPS, IAEEH, and the withholding of withholdings, through the SAT Portal, via the "Declarations and Payments" Service, according to the following:
I. to VI.
...
...
CFF 6o., 20, 31, LISH 56, RCFF 41, RMF 2.1.18., 2.4., 2.5.
Procedure for filing declarations of provisional or definitive payments of DEPEBI
2.8.3.7.
For the purposes of articles 20, seventh paragraph, 31, first paragraph of the CFF, 41 of its Regulation, 7o. of the LIF, as well as 39, 40 and 52 of the LISH, state-owned enterprises that are obligated to pay DEPEBI will file the normal declarations, including their complementary, late, and fiscal correction declarations, through the SAT Portal, via a clarification case, in accordance with procedure form 13/LISH "Declarations of payment of the petroleum right for well-being", contained in Annex 1-A, and must attach to said declaration the official form "DEPEBI", contained in Annex 1, as well as the respective payment receipt.
...
...
CFF 20, 31, LISH 39, 40, 52, RCFF 41, LIF 7o.
Filing of merger and spin-off reports of companies
2.10.27.
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...
...
...
I. and II.
...
III.
State-owned enterprises.
CFF 14-B, 32-A
Request for installment payments of fines not reduced in accordance with article 74 of the CFF
2.14.9.
...
I. and II.
...
III.
The taxpayer must pay at least 20% of the total of the updated omitted contributions and their accessories and/or the revenues and their accessories other than those incurred due to the import and export of goods or services that have been authorized for installment payment, within a maximum period of ten business days following the notification of the authorization of the fine reduction in accordance with article 74 of the CFF with installment payment.
IV. to VII.
...
CFF 66, 66-A, 74, RCFF 65, RMF 2.14.8.
Reduction of fines in accordance with article 74 of the CFF, for non-compliance with federal tax obligations other than payment obligations, due to oversight in the matter of filing declarations
2.14.14.
For the purposes of article 74 of the CFF, regarding fines derived from the oversight procedure for obligations in the matter of filing declarations, the following shall apply:
I.
When the authority verifies that the taxpayer fulfilled the obligation and the fine or fines had not been notified, they will be considered reduced to 100%.
II.
If the fine or fines had already been notified, they will also be considered reduced to 100%, provided that the taxpayer has fulfilled the obligation, before the authority had initiated the administrative execution procedure for its collection.
III.
When the tax authority has initiated the administrative procedure of execution, the percentage of fine reduction will be determined as follows, provided that the taxpayer has previously fulfilled the obligation:
a)
...
b)
...
If not, the authority may continue with the administrative execution procedure.
c) to e)
...
...
...
...
It will be understood that the taxpayer fulfilled the obligation if they filed the omitted declaration or declarations and, if applicable, paid the amount.
...
CFF 74, RMF 2.14.6., 2.14.7.
Requirements to request authorization to issue electronic wallets used in the acquisition of fuels for maritime, aerial, and land vehicles
3.3.1.8.
...
I. to VII.
...
VIII.
If the applicant for authorization to be the issuer of the electronic wallet is the gas station, it must hold a valid permit, issued by the National Energy Commission, and that, if applicable, is not suspended at the moment of the request.
...
...
...
...
...
...
...
...
...
LISR 27, RMF 3.3.1.6., 3.3.1.9., 3.3.1.36.
Obligations of the authorized issuer of electronic wallets used in the acquisition of fuels for maritime, aerial, and land vehicles
3.3.1.10.
...
I. to VI.
...
VII.
Affiliate gas stations that hold a valid permit issued in accordance with the terms of the LSH as fuel providers, through the celebration of contracts, in order for the electronic wallet to be used at said gas stations in the acquisition of fuels for maritime, aerial, and land vehicles, using for such purposes the prototypes presented in accordance with procedure form 6/ISR "Request for authorization to issue electronic wallets", contained in Annex 1-A. Likewise, they must publish on their Internet page a list of the affiliated gas stations.
...
VIII. to XII.
...
LISR 27, CFF 28, 29, 29-A, 30, 32-I, RMF 2.7.1.8., 3.3.1.7., 3.3.1.8.
Option to deduct expenses and non-deductible investments for taxpayers under the regime of agricultural, livestock, forestry, and fishing activities
3.3.1.24.
...
...
...
Taxpayers who start activities and those who have already exercised the option referred to in this rule, must file a clarification case in the SAT Portal, through Mi portal, selecting "AVISO DEDUC AGAPES SIN PROPORC" and from the month in which they exercise said option, they will consider in the determination of the provisional payment, the totality of the income of the period from the start of the fiscal year and until the last day of the month to which the payment corresponds, accumulating to said income the amount of exempt income referred to in the first paragraph of this rule.
LISR 28, 74, 77, RMF 2.4.
Option not to file the informational declaration of operations with related parties
3.9.18.
...
The foregoing will not be applicable to those residents in Mexico who carry out operations with companies or entities subject to preferential tax regimes, as well as to the contractors referred to in the LISH.
LISR 76, 110
Option not to withhold ISR for the concept of use or temporary enjoyment of real estate for residents in the United States of America
3.18.5.
...
...
Foreign residents who obtain income from the use or temporary enjoyment of their real estate, who wish to be included in the list on the SAT Portal, must manifest their willingness to opt to determine the ISR in accordance with what is established in procedure form 22/ISR "Notice to opt to determine the tax on a net basis", contained in Annex 1-A and request the inclusion of their data in the SAT Portal. In any case, foreign residents must prove their residence for tax purposes in the United States of America.
Once they are published in the list on the SAT Portal, and if they wish to continue applying the option in subsequent fiscal years, they must file in the months of January and February of each year, a notice in accordance with what is established in procedure form 53/ISR "Notice that must be filed in the months of January and February of each year, regarding the option not to withhold ISR for the concept of use or temporary enjoyment of real estate for residents in the United States of America", contained in Annex 1-A.
...
MEXICO-USA TREATY 6, LISR 4, 158, CFF 18, 19, RLISR 6, RMF 3.1.3.
Conversion of investment trusts in energy and infrastructure into investment trusts of state-owned enterprises in the electric industry
4.3.11.
For the purposes of article 9o., subsection VII of the VAT Law, in relation to rule 3.21.2.8., VAT will not be paid for the alienation of fiduciary rights carried out in accordance with rules 3.21.2.2. and 3.21.2.8., between state-owned enterprises in the electric industry and trusts that meet the requirements of rule 3.21.2.1.
LIVA 9o., RMF 3.21.2.1., 3.21.2.2., 3.21.2.8.
Informational declaration of operations with third parties filed by natural and legal persons, format, period, and means of filing
4.5.1.
...
...
...
I.
The petroleum operator must relate the amount of the totality of the operations carried out in their capacity as petroleum operator of a consortium or of the assignee designated as petroleum operator of a unified area; as well as the amount of those operations carried out on their own account.
II.
The non-operator members of a consortium or the contractor designated as petroleum operator of the consortium that is part of a unified area, must relate the amount of the operations covered by the respective CFDI that the petroleum operator of a consortium or the assignee designated as petroleum operator of a unified area had issued to them in accordance with rules 10.5. or 10.32., as applicable; as well as the amount of those operations carried out individually.
...
...
...
...
LIVA 5o., LIVA 2021 5o.-E, 32, LISH 31, 32, RMF 4.5.2., 10.5., 10.32.
Assignment of key to produce and import new brands of carved tobaccos
5.2.27.
Producers and importers of carved tobaccos who during the fiscal year in question launch brands different from those classified in Annex 11, will assign a new key, in accordance with what is established in item a) Catalogs of keys and brands of carved tobaccos current in the section "Keys of carved tobacco brands" of Section B. "Catalogs of keys of generic names of alcoholic beverages and brands of carved tobaccos" of said Annex 11, and must file the notice referred to in procedure form 30/IEPS "Notices filed by producers and importers of carved tobaccos", contained in Annex 1-A. For such purposes, taxpayers must prove that they hold the rights to the new brands they launch to the market, or that they hold the rights to carry out the import and commercialization in national territory of said brands; likewise, they must present a sample to the tax authority, of each new brand to which they assign a key, in accordance with the aforementioned procedure form.
The assignment of keys for carved tobacco brands referred to in the previous paragraph, must be renewed every year in accordance with the form cited in said paragraph.
...
...
Additionally, producers and importers of carved tobaccos obligated to present information through the Electronic Program "Multiple Informational Declaration of the Special Tax on Production and Services" (MULTI-IEPS), must be up to date in the fulfillment of said obligation.
The tax authority may require taxpayers to provide additional data, reports, or documents that it considers necessary and that are related to the procedures referred to in this rule.
LIEPS 19
Declarations of Petróleos Mexicanos
9.1.
For the purposes of article 7o., first paragraph of the LIF, Petróleos Mexicanos must file the declarations and payments that correspond to it in accordance with Title First, Chapter XIII, Second Section and Title Second, Chapters VIII, IX and XIV of the LFD, article 10 of the LIF, as well as articles 6o., 7o. and 11 of the Law of Contributions for Improvements by Federal Public Works of Hydraulic Infrastructure, which are administered by CONAGUA, in accordance with the procedure indicated in rules 2.8.5.1. and 2.8.1.10., as well as procedure form 90/CFF "Declaration and payment of rights, products, and revenues", contained in Annex 1-A, before CONAGUA.
LIF 7o., 10, Law of Contributions for Improvements by Federal Public Works of Hydraulic Infrastructure 6o., 7o., 11, RMF 2.8.1.10., 2.8.5.1.
Application of the tax incentive in declarations
9.22.
For the purposes of the Thirty-Fourth Transitional, second paragraph, subsection I, item a) of the LIF, taxpayers may apply the "Tax Regularization Incentive of the LIF" in the section of "Payment" or "Payment Determination" of the forms of the declarations corresponding under the following procedure:
I.
Log in to the SAT Portal (www.sat.gob.mx).
II.
Select the section Procedures and services.
III.
Choose the subsections "Declarations for individuals" or "Declarations for companies", as applicable.
IV.
Select the section "Provisional and definitive" or "Annual".
V.
From the options that appear in the section, select the form of the declaration to be filed in accordance with the taxation regime.
VI.
Fill out the declaration by capturing the enabled data or validating the information of the pre-filled declarations.
VII.
Enter the section "Payment" or "Payment Determination", to the form that appears.
VIII.
In the field "Do you have incentives to apply?", or "Do you wish to apply any compensation or tax incentive?" select "Yes".
IX.
Select the option "Tax Regularization Incentive".
X.
Subsequently, in the field "To be applied in the period" or in the field "Amount" capture the amount of the incentive you have determined in working papers.
XI.
Save and continue with the filing of the declaration until submission.
LIF Thirty-Fourth Transitional
Fiscal receipts for costs, expenses, or investments made by consortiums
10.5.
...
...
I.
The contract number assigned by the Ministry of Energy with which the expense is linked.
II. to X.
...
LISH 31, 32, CFF 29, 29-A, RMF 2.7.1.14.
Fiscal receipts for the consideration received by consortiums
10.6.
...
...
I.
The contract number assigned by the Ministry of Energy from which the respective consideration derives.
II. to VI.
...
...
LISH 31, 32, CFF 29, 29-A
Deadline for sending information incorporated into the registry
10.7.
Repealed.
Start of activities destined to the commercial production of hydrocarbons
10.9.
For the purposes of article 55, second paragraph of the LISH, it will be understood that the start of activities destined to the commercial production of hydrocarbons occurs at the moment the notification to the contractor or assignee of the first development plan for the Extraction of the contractual area or assignment area that corresponds, approved by the Ministry of Energy, takes effect.
In accordance with what is stated in article 56, third paragraph of the LISH, the Ministry of Energy will provide the SAT with the information of the date of notification of the first development plan for the extraction of hydrocarbons that it has approved to each assignee or contractor, in accordance with procedure form 8/LISH "Notice of the notification of the development plans for the extraction of hydrocarbons approved by the Ministry of Energy for the determination of the IAEEH", contained in Annex 1-A.
...
LISH 55, 56, RMF 10.13.
Deadline for filing the payment declaration of the hydrocarbon exploration right
10.10.
Repealed.
Fee of the hydrocarbon exploration right per fraction of a month
10.11.
Repealed.
Deduction percentage for enhanced recovery
10.12.
Repealed.
Concept of hydrocarbon activities
10.14.
For the purposes of article 64, first paragraph of the LISH, the activities referred to in the LSH are those related in its article 3, regardless of the quality of the foreign resident carrying them out.
LISH 64, LSH 3, RMF 10.15.
Computation of days of duration of the activities referred to in the LSH
10.15.
...
...
LISH 64, RLISH 36, RMF 10.14.
Concept of employment related to activities of contractors or assignees
10.17.
For the purposes of article 64, fourth paragraph of the LISH, it will be considered that an employment is related to the activities of the contractors or assignees referred to in the LSH, among others, in the following cases:
I.
When the service is provided to legal persons, consortiums, or partnerships that have the quality of contractor or assignee in accordance with the terms of the LSH.
II.
When the service is provided to persons considered as related parties, in accordance with article 179 of the Income Tax Law, of the entities referred to in subsection I of this rule.
III.
When the object or predominant activity of the one making the payments is the recognition and surface exploration or the exploration and extraction of hydrocarbons, in accordance with the LSH.
LISH 64, LISR 154, 179, RMF 10.18.
Update of the IAEEH established in the LISH
10.19.
For the purposes of article 55 of the LISH, the fees established that will be applicable from January 1, 2025, were updated considering the period from the month of December 2023 to the month of December 2024. The result obtained is made known in Annex 27.
In accordance with what is exposed in the first paragraph of this rule, the update carried out was made according to the following procedure:
For the fees established in article 55, first paragraph, subsections I and II of the LISH, the period considered for their update is that between the month of December 2023 and the month of December 2024. In these terms, the factor of update applicable to the mentioned period was obtained by dividing the INPC of the month immediately preceding the most recent of the period, by the INPC corresponding to the month preceding the oldest of the period, so the INPC of the month of November 2024 was considered, which was 137.424 points, published in the DOF on December 10, 2024, and the INPC of the month of November 2023, published in the DOF on December 08, 2023, which was 131.445 points. As a result of this operation, the update factor obtained and applied was 1.0454.
LISH 55, RMF 1.9.
Return of VAT balances in favor for taxpayers who have the quality of contractors in terms of the LSH
10.20.
For the purposes of articles 6o. of the VAT Law and 22, first and seventh paragraphs of the CFF, taxpayers who have the quality of contractors in accordance with the LSH, may obtain the return of VAT balances in favor within a maximum period of twenty days counted from the next business day following the date of the filing of the corresponding request, provided that:
I.
...
II.
...
Se encuentren al corriente in the fulfillment of their tax obligations and those derived from contracts entered into with the Ministry of Energy.
III.
The requested credit balance must have been generated and declared from the signing of the Contract for the Exploration and Extraction of Hydrocarbons entered into with the Ministry of Energy.
IV. to IX.
...
...
...
...
LIVA 5th, 6th, CFF 17-H, 17-H Bis, 22, 22-A, 22-D, 69, 69-B, RMF 2.3.4., 2.8.1.5.
Assignment area that is not in the production phase
10.22.
Repealed.
Definition of pre-operational period for the hydrocarbon industry
10.24.
...
The expenses and investments referred to in this rule must be directly related to the contractual areas determined by the Ministry of Energy in accordance with Article 58 of the LSH.
LSH 5, 58, LIVA 5th.
Pre-operational period for contractor companies in the hydrocarbon industry
10.25.
For the purposes of Article 5th, fraction VI, fifth paragraph of the VAT Law, companies in the hydrocarbon industry that have signed a Contract for the Exploration and Extraction of Hydrocarbons, in any of the modalities established in the LSH, will consider as expenses and investments carried out in the pre-operational period those mentioned in rule 10.24.
The pre-operational period of the contractors will conclude at the moment they receive the first consideration from the FMP, corresponding to the regular commercial production of hydrocarbons, in accordance with what is established in the respective Contract for the Exploration and Extraction of Hydrocarbons. It will not be considered that the pre-operational period has concluded when considerations are received for the obtaining of hydrocarbons in the production of any test to determine the characteristics of the reservoir and production flows.
...
LSH 5, LIVA 5th, 18, RMF 10.24.
Determination of the value of the consideration received by contractors in kind from the State
10.26.
For the purposes of Article 34 of the VAT Law, the companies referred to in rule 10.25, second paragraph, will consider as the market value of the in-kind considerations they receive from the FMP, derived from the Contract for the Exploration and Extraction of Hydrocarbons they have signed, the value that corresponds to said considerations in terms of the respective contract at the moment they receive them.
LIVA 34, RMF 10.25.
Cash payment contained in the economic proposal of the bidding bases issued by the Ministry of Energy
10.27.
For the purposes of Articles 4, second paragraph of the LISH, 58-A, fraction II of the CFF, as well as 27, fraction XIII and 28, fraction XII of the Income Tax Law, the taxpayer who has been selected in accordance with the bases of the bidding procedure issued by the Ministry of Energy and signs a Contract for the Exploration and Extraction of Hydrocarbons that results from the migration of an assignment in terms of the procedure established in Articles 54 and 55 of the LSH, may consider that the cash amount paid to a public company of the State for the concept of investments, corresponds to the price or market value and does not constitute a commercial credit.
LSH 54, 55, LISH 4, LISR 27, 28, CFF 58-A
Operation of the assignee designated as the petroleum operator of a unified area
10.28.
For the purposes of Articles 29 and 29-A of the CFF, as well as Article 86, fraction II of the Income Tax Law, the assignee that is designated as the petroleum operator of a unified area, will be subject to the following:
I.
The CFDIs issued to support the costs, expenses, and investments made for the development of activities necessary for the execution of the Agreement or Resolution of Unification, approved or issued by the Ministry of Energy, as applicable, must be issued in the name of the assignee that has been designated as the petroleum operator of a unified area, in accordance with said Agreement or Resolution.
II.
It must deliver to the contractor designated as the petroleum operator of a consortium that is part of a unified area, a list of the operations it carries out under the Agreement or Resolution of Unification, approved or issued by the Ministry of Energy, as applicable, and must keep a copy of the same, as well as the fiscal receipts that support these operations.
III.
It must issue to the contractor designated as the petroleum operator of a consortium that is part of a unified area and to itself, the CFDIs that support the proportional part corresponding to the costs, expenses, and investments made in each period derived from the execution of the Agreement or Resolution of Unification, approved or issued by the Ministry of Energy, as applicable, which must include the complement referred to in rule 10.32.
IV.
It must provide, no later than February 15 of each year, to the AGH, the information of the operations carried out in the immediate previous year on behalf of the petroleum operator contractor of the consortium that is part of a unified area, identifying the proportional part that corresponds to it of the total of the operations carried out in accordance with what is established in the Agreement or Resolution of Unification, approved or issued by the Ministry of Energy, as applicable, in accordance with the procedure form 11/LISH "Informational declaration of operations carried out on behalf of the members of the petroleum consortium or of a unified area", contained in Annex 1-A, taking into consideration that it must provide the data corresponding to the unified area.
V.
It must comply with its tax obligations individually, including what is established in the Second Transitional Provision of the "Decree by which various provisions of the Hydrocarbon Income Tax Law are reformed, added, and repealed", published in the DOF on March 18, 2025.
LSH 70, LISR 86, CFF 29, 29-A, RLH 63, 64, Decree DOF 18/03/2025 Second Transitional Provision,
RMF 10.32.
Operation of the contractor when an assignee is designated as the petroleum operator of a unified area
10.29.
For the purposes of Articles 4, second paragraph of the LISH, 29 and 29-A of the CFF, as well as 16 and 25 of the Income Tax Law, regarding the determination of Income Tax, the contractor designated as the operator of a consortium that is part of a unified area, in which an assignee is designated as the petroleum operator, will be subject to the following:
I.
It may deduct, individually, the proportional part of the costs, expenses, and investments that are made, provided that the CFDI issued by the assignee designated as the petroleum operator of a unified area supports the amount of the proportional part that corresponds to said contractor member of a unified area and the requirements established by the tax provisions are met.
II.
...
III.
It must issue the CFDIs referred to in Article 32, section B, fraction III of the LISH to the members of the consortium, in accordance with rule 10.5., which must support the costs, expenses, and investments made in each period derived from the execution of the Agreement or Resolution of Unification, approved or issued by the Ministry of Energy, as applicable, that each member of the consortium has effectively covered, which must coincide with the costs, expenses, and investments of the CFDI, issued by the assignee designated as the petroleum operator of a unified area, referred to in rule 10.28, fraction III.
LISH 4, 32, LSH 70, LISR 16, 25, CFF 29, 29-A, RMF 10.5., 10.28.
Determination of VAT by the assignee designated as the petroleum operator of a unified area
10.30.
For the purposes of Articles 46, second paragraph of the LISH, 1st, 4th, 5th and 18 of the VAT Law, for the determination of VAT, the assignee that is designated as the petroleum operator of a unified area, will be subject to the following:
I.
It will not consider as the value of acts or activities to calculate VAT, in the case of the provision of services, the amounts it receives to make expenses on behalf of the contractor designated as the petroleum operator of a consortium that is part of a unified area, and
II.
...
LISH 46, LIVA 1st, 4th, 5th, 18, RMF 10.28., 10.32.
Determination of creditable VAT by the contractor designated as the operator of the consortium that is part of a unified area where an assignee is the petroleum operator
10.31.
For the purposes of Articles 4, second paragraph of the LISH, 4th, 5th and 18 of the VAT Law, for the determination of VAT, the contractor designated as the operator of the consortium that is part of a unified area in which an assignee is designated as the petroleum operator, may credit, individually, the proportional part of the total of the creditable VAT that corresponds to it, provided that said assignee issues the CFDI that complies with rule 10.32 and the other requirements established in the VAT Law, its Regulations, and other tax provisions for credit purposes are met.
...
LISH 4, LIVA 4th, 5th, 18, RMF 10.4., 10.28., 10.32.
Fiscal receipts for costs, expenses, or investments made by the assignee designated as the petroleum operator of a unified area
10.32.
For the purposes of Articles 86, fraction II of the Income Tax Law, 29 and 29-A of the CFF, the CFDIs issued by the assignee designated as the petroleum operator of a unified area, in favor of the contractor designated as the operator of a consortium that is part of said unified area, in order to support the costs, expenses, and investments made derived from the execution of the Agreement or Resolution of Unification, approved or issued by the Ministry of Energy, as applicable, may be issued monthly, provided that they include the operations that had been carried out in the corresponding calendar month and are issued before the deadline to present the declarations of said month is met.
Both the CFDIs issued monthly in terms of the preceding paragraph, and those issued without exercising this option, must incorporate the Complement "Expenses of the consortium derived from the Execution of a Contract for Exploration or Extraction of Hydrocarbons", published on the SAT Portal, and must contain the following information corresponding to the assignee designated as the petroleum operator of a unified area:
I. and II.
...
III.
The reference that the CFDI referred to in this rule is linked to the CFDIs or fiscal receipts that comply with rule 2.7.1.14., issued in favor of the assignee designated as the petroleum operator of a unified area due to the costs, expenses, or investments made under the Agreement or Resolution of Unification, approved or issued by the Ministry of Energy, as applicable.
...
IV.
The fiscal folio number and date of issuance of the fiscal receipts issued in favor of the assignee designated as the petroleum operator of a unified area with which it is linked.
V.
...
VI.
Amount of each of the costs, expenses, or investments made that make up the total amount of the CFDI issued to the consortium operator contractor that is part of a unified area and that are supported in the CFDI or in the fiscal receipts that comply with rule 2.7.1.14., issued in favor of the assignee designated as the petroleum operator of a unified area.
Likewise, the key in the RFC of the provider that issued the CFDI in favor of the assignee designated as the petroleum operator of a unified area, with which the cost, expense, or investment is linked, must be indicated.
Additionally and in the case of the receipts mentioned in the preceding paragraph, to which rule 2.7.1.14. refers, the tax identification number of the provider that issued the fiscal receipt in favor of the assignee that is designated as the petroleum operator of a unified area, with which the cost, expense, or investment is linked, must be indicated.
VII. to IX.
...
X.
The amount of the withholding of Income Tax, VAT, and, if applicable, other taxes, that appear in the CFDI issued in favor of the assignee designated as the petroleum operator of a unified area.
...
LISR 86, CFF 29, 29-A, RMF 2.7.1.14., 10.5.
Assignments, contracts, permits, accreditations, or recognitions granted or entered into prior to the entry into force of the LSH
10.33.
For the purposes of the Tenth Transitional Article of the LSH, what is established in rules 2.6.1.2., 10.5., 10.6., 10.9., 10.20. and 10.32. will continue to be applicable to taxpayers who have assignments and contracts for the Exploration and Extraction of Hydrocarbons that had been granted or entered into prior to the entry into force of the LSH, until the aforementioned assignments and contracts conclude with their validity.
Likewise, for the purposes of the Thirteenth Transitional Article of the LSH and the Eighth Transitional Article of the Law of the National Energy Commission, regarding permits to carry out activities of the Hydrocarbon industry, as well as the accreditations or recognitions issued prior to the entry into force of the aforementioned Laws, what is established in rules 2.6.1.2., 2.6.1.6., 2.7.7.2.4., 3.3.1.8.,
3.3.1.10., 11.6.1. and 11.7.1. will continue to be applicable as long as they maintain their validity in the terms granted.
LSH Transitional Tenth, Thirteenth, Law of the National Energy Commission
Transitional Eighth, RMF 2.6.1.2., 2.6.1.6., 2.7.7.2.4., 3.3.1.8., 3.3.1.10.,10.5., 10.6., 10.9.,
10.20., 10.32., 11.6.1., 11.7.1.
Packaging for the conservation of sculptures
11.1.9.
...
...
In the case of paintings or engravings that due to their characteristics cannot be framed, they may be delivered in a wooden packaging that complies with the same specifications indicated in this rule.
Decree 31/10/94 Fourth
Fiscal incentive for taxpayers who sell gasoline and diesel to members of the fishing and agricultural sector
11.6.1.
...
I.
...
II.
Sell gasoline or diesel to persons who hold permits issued by the National Energy Commission, for the public sale of petroleum products at gas stations, and who in their capacity as authorized distributors by the National Commission of Aquaculture and Fisheries (CONAPESCA), or by the Ministry of Agriculture and Rural Development (SADER), sell said fuels to members of the fishing or agricultural sector registered in the Register of Beneficiaries of Agricultural Fuels kept by CONAPESCA or in the Register of Beneficiaries of Agricultural Diesel kept by SADER, respectively.
LIEPS 2nd, Agreement DOF 30/12/2015
Return of the incentive or its excess of creditable amount
11.7.1.
...
A.
...
I. and II.
...
III.
...
a) to f)
...
g)
...
Valid and non-suspended permit(s)
issued by the National Energy Commission,
for the public sale of petroleum products at gas stations, which include each of the gas stations located in the geographic zones
subject to the incentives, and must be
presented each time it is modified or updated.
- and 3.
...
...
B.
...
...
CFF 17-H, 17-H Bis, 22, 22-D, 25, 28, 32-D, 69, 69-B, 69-B Bis, LISR 27, LIVA 32, LIEPS 2,
19, RCFF 33, 34, Decree IEPS fuels. DOF 27/12/2016 Second, Third, Fifth,
Decree IEPS fuels southern border. DOF 28/12/2020 First, Second, Third,
Decrees northern and southern border region DOF 30/12/2020, RMF 2.1.36., 2.8.1.5.
Application of the immediate deduction of investment in new fixed asset goods in the provisional payments of the 2025 exercise
11.15.5.
For the purposes of Articles First, first, second and eighth paragraphs of the Decree referred to in this Chapter, taxpayers may apply the immediate deduction of investment in new fixed asset goods, in the provisional payments of the fiscal year 2025, in the provisional payment forms that correspond to them according to the regime under which they tax, as follows:
I.
In the field "Immediate deduction of investments", in the option "Capture", a pop-up window named "Immediate deduction of investments of the period" will appear.
II.
In the tab "Decree Relocation/Mexico Plan", the amount to be applied in the field "Immediate deduction of investments of the month" can be captured.
Decree DOF 21/01/2025 First
Chapter 11.17. Of the Decree by which fiscal incentives are granted in the Economic Development Poles for Welfare, published in the DOF on May 22, 2025 and its modification published in the DOF on July 31, 2025
11.17.1.
Of the application of the fiscal incentive to natural persons
For the purposes of Article First, first paragraph of the Decree referred to in this Chapter, it will be considered that natural persons who tax in terms of Title IV, Chapter II, Section I of the Income Tax Law, begin operations on the date of registration in said regime, for the carrying out of economic activities inside the PODECOBI.
Decree PODECOBI DOF 22/05/2025 First
Specific registration of fiscal incentives
11.17.2.
For the purposes of Articles Third, last paragraph and Fourth, last paragraph of the Decree referred to in this Chapter, the specific registration that taxpayers who opt to apply the fiscal incentives established in said Decree must keep, will be integrated by the documentation indicated in Article Second of the Decree, the information and documentation established in the PODECOBI Guidelines, as well as by the following:
I.
In the case of the immediate deduction of investment in new fixed asset goods, with the accounting register policy of the operation, working papers, and the supporting documentation that backs up the expenditure, which allow identifying the date of acquisition of the good, its description, that it is a new good for the purposes of the referred Decree, and, if applicable, the validity of the contract if the goods were granted in loan for use in accordance with Articles Second, section A, fraction III and Fourth, fourth and fifth paragraphs of the Decree referred to in this Chapter; the original amount of the investment, its update, and the amount of its immediate deduction, the relationship that the good has with its productive economic activities carried out exclusively inside the pole in question, the process or specific activity in which it was used; the year in which the deduction was applied, and, if applicable, the date on which the good was sold, lost due to fortuitous event or force majeure, or ceased to be useful, as well as the supporting documentation thereof.
II.
Regarding the additional deduction of training expenses, with the policies of the accounting registers of said expenses, working papers, and supporting documentation, which allow identifying what the training expenses consisted of that provided technical or scientific knowledge linked to the taxpayer's activity, the relationship they have with the taxpayer's activities carried out exclusively inside the pole in question, the list of active workers registered with the IMSS that received the training and their amount in the year in which the fiscal incentive indicated in Article Fourth of the Decree referred to in this Chapter was opted for, and, if applicable, the amount of the training expenses made in the year or years that were taken into account to determine the increase in accordance with the first paragraph of said article, as well as the amount of the corresponding increase on which the 25% percentage and the additional deduction of training expenses were applied.
III.
Regarding the additional deduction of expenses for the concept of innovation, with the policies of the accounting registers of said expenses, working papers, the records corresponding to patents, utility models, and initial certifications that, if applicable, are generated, and the supporting documentation that backs up the expenditure, which allows identifying what the aforementioned expenses consisted of, the relationship they have with the economic activities carried out exclusively inside the pole in question, the way in which their processes were improved, and the link with the investment project that was authorized in accordance with the Decree referred to in this Chapter, the amount in the year in which the fiscal incentive indicated in Article Fourth of the Decree referred to in this Chapter was opted for, and, if applicable, the amount of the expenses made in the year or years that were taken into account to determine the increase, in accordance with the first paragraph of said article, as well as the amount of the corresponding increase on which the 25% percentage and the additional deduction of expenses for the concept of innovation were applied.
The information indicated in this rule will form part of the accounting and must be kept available to the authorities in accordance with Articles 28 and 30 of the
CFF.
CFF 28, 30, Decree PODECOBI DOF 22/05/2025 and 31/07/2025 Second, Third, Fourth,
PODECOBI Guidelines DOF 22/05/2025
Payment of the tax for non-compliance with the requirements or revocation of the authorization to apply the fiscal incentives
11.17.3.
For the purposes of Article Second, last paragraph of the Decree referred to in this Chapter and of the PODECOBI Guidelines, taxpayers who have opted to apply the fiscal incentives and have failed to comply with the requirements of the Decree, its Guidelines, rule 11.17.2., or whose authorization has been revoked in terms of Chapter Eight of the Guidelines, as applicable, must cover the tax corresponding to the difference between the amount deducted in accordance with Articles Third and Fourth of said Decree and the amount that should have been deducted, in case of not applying said fiscal incentives, as applicable, in terms of the Income Tax Law, for which the corresponding complementary declaration(s) must be presented and the respective payment made, within the month following that in which the requirements for the application of the fiscal incentives cease to be met or, if applicable, their authorization referred to in the last paragraph of Article First of said Decree is revoked.
LISR 34, 35, 104, 209, Decree PODECOBI DOF 22/05/2025 and 31/07/2025 First,
Second, Third, Fourth, PODECOBI Guidelines DOF 22/05/2025 Chapter Eight
Documentation to prove that the acquired fixed asset goods are new
11.17.4.
For the purposes of Articles Third, first and second paragraphs of the Decree referred to in this Chapter, taxpayers may prove that the fixed asset goods that
acquired are new considerations, among others, the following documents:
I.
CFDI that complies with the requirements of article 29-A of the CFF, which supports the
acquisition, which must have as the acquisition date that from which the
federative entity signs and publishes the coordination agreement, or from
that they have been authorized as developers by the federative entity, in terms of the articles Tenth and Eleventh of the Decree
to which this Chapter refers, respectively, and until September 30,
II.
Bank statement showing the corresponding payment.
III.
Accounting register policy.
IV.
If applicable, contract in which the qualitative characteristics of the
asset, origin and information with which its physical condition can be determined,
in the case of acquisitions of assets that are carried out differently from
importation.
V.
The supporting documentation that describes the type of asset in question, the
relationship with the taxpayer's productive economic activity, which is carried out
exclusively within the pole in question and the process or activity in
specific in which the asset was used.
VI.
In the case of fixed assets coming from abroad, taxpayers
may prove their acquisition through the receipt
issued by the resident abroad in accordance with rule 2.7.1.14.,
import declaration and its annexes, as well as with the bank statement
in which the corresponding payment is recorded.
In the case of goods that are used for the first time in Mexico, the fiscal receipt or the
documentation in question, must support that the good does not have an age greater
to two years of useful life.
The documentation referred to in this rule will be part of the accounting in terms
of articles 28 and 30 of the CFF.
The provisions of this rule do not relieve taxpayers of compliance with the requirements
established in the tax legislation on investment deductions.
CFF 28, 29-A, 30, LA 36, 36-A, Decree PODECOBI DOF 22/05/2025 and 31/07/2025 Third,
Tenth, Eleventh, PODECOBI Guidelines DOF 22/05/2025, RMF 2.7.1.14.
Chapter 11.18. Of the Decree by which fiscal benefits are granted in the Poles
of
Circular Economy Development for Well-being, published in the
DOF on July 04
of 2025
Specific record of fiscal incentives
11.18.1.
For the purposes of articles 11, last paragraph and 14, last paragraph of the Decree to which
this Chapter refers, the specific record that taxpayers who opt
to apply the fiscal incentives established in said Decree must keep, will be integrated by the
documentation indicated in article 9 of the Decree, the information and documentation
established in the PODECIBI Guidelines, as well as by the following:
I.
In the case of the immediate deduction of investment in new fixed assets,
the accounting register policy of the operation, working papers and the
supporting documentation that backs up the expenditure, which allow identifying
the date of acquisition of the asset, its description, that it is a new
asset for the purposes of the referred Decree; the original amount of the investment, its
update and amount of its immediate deduction, the relationship that the asset
has with its productive economic activities carried out exclusively within
the pole in question, the process or specific activity in which it was used;
the year in which the deduction was applied and, if applicable, the date on which the
asset was alienated, lost due to fortuitous event or force majeure or ceased to be useful, as
well as the supporting documentation thereof.
II.
Regarding the additional deduction of training expenses, with the policies of
the accounting records of said expenses, working papers and
supporting documentation, which allow identifying what the
training expenses consisted of, which provided technical or scientific knowledge
linked to the exclusive economic activities carried out within
the PODECIBI circular economy companies and developers, the list
of active workers registered with the IMSS who received the
training and its amount in the year in which the option was taken to apply the fiscal incentive
indicated in article 11 of the Decree to which this Chapter refers and, if
applicable, the amount of training expenses incurred in the year or in the
previous years that were taken into account to determine the
increase referred to in the second paragraph of said article and rule
11.18.4., as well as the amount of the corresponding increase on which the
25% percentage and the additional deduction of training expenses were applied.
III.
Regarding the additional deduction of expenses for the concept of innovation, with
the policies of the accounting records of said expenses, working papers,
the corresponding records of patents and initial certifications that, if any,
generated and the supporting documentation that backs up the expenditure,
which allows identifying what the aforementioned expenses consisted of, the relationship
that they have with the economic activities carried out within
the PODECIBI, the amount in the year in which the option was taken to apply the fiscal incentive
indicated in article 11 of the Decree to which this Chapter refers and, if
applicable, the amount of expenses incurred in the year or in the years that
were taken into account to determine the increase, in accordance with the second
paragraph of said article and rule 11.18.4., as well as the amount of the
corresponding increase on which the 25% percentage and the
additional deduction of expenses for the concept of innovation were applied.
The information indicated in this rule will be part of the accounting and must be
kept available to the authorities in accordance with articles 28 and 30
of the
CFF.
CFF 28, 30, Decree PODECIBI DOF 04/07/2025 9, 11, 14, PODECIBI Guidelines DOF
21/07/2025, RMF 11.18.4.
Payment of tax for non-compliance with requirements or revocation of
authorization to apply fiscal incentives
11.18.2.
For the purposes of article 9, third and fifth paragraphs of the Decree to which this
Chapter refers and of the PODECIBI Guidelines, taxpayers who have opted to apply
the fiscal incentives and have failed to comply with the requirements of said Decree and of
its Guidelines, or whose authorization has been revoked in terms of Chapter
Eleventh of the PODECIBI Guidelines, as applicable, must cover the
tax corresponding to the difference between the amount deducted in accordance with articles
11 and 14 of said Decree and the amount that should have been deducted, in the event of not applying said
fiscal incentives, as applicable, in terms of the ISR Law, for which
the corresponding complementary declaration(s) must be filed and the
respective payment made, within the month following that in which the requirements cease to be met,
or on the date on which the non-compliance resolution is issued.
Decree PODECIBI DOF 04/07/2025 9, PODECIBI Guidelines DOF 21/07/2025
Documentation to prove that acquired fixed assets are new
11.18.3.
For the purposes of article 14 of the Decree to which this
Chapter refers, taxpayers may prove that the fixed assets they acquired are new
considering, among others, the following documents:
I.
CFDI that complies with the requirements of article 29-A of the CFF, which supports the
acquisition, which must have as the acquisition date from July 04
of 2025, the date of entry into force of the Decree to which this
Chapter refers and until December 31, 2030.
II.
Bank statement showing the corresponding payment.
III.
Accounting register policy.
IV.
If applicable, contract in which the qualitative characteristics of the
asset, origin and information with which its physical condition can be determined,
in the case of acquisitions of assets that are carried out differently from
importation.
V.
The supporting documentation that describes the type of asset in question, the
relationship with the activities carried out within the PODECIBI and the process or
specific activity in which the asset was used.
VI.
In the case of fixed assets coming from abroad, taxpayers
may prove their acquisition through the receipt
issued by the resident abroad in accordance with rule 2.7.1.14.,
import declaration and its annexes, as well as with the bank statement
in which the corresponding payment is recorded.
In the case of goods that are used for the first time in Mexico, the fiscal receipt or the
documentation in question, must support that the good does not have an age greater
to two years of useful life.
The documentation referred to in this rule will be part of the accounting in terms
of articles 28 and 30 of the CFF.
The provisions of this rule do not relieve taxpayers of compliance with the requirements
established in the tax legislation on investment deductions.
CFF 28, 29-A, 30, Decree PODECIBI DOF 04/07/2025 14
Procedure to determine the additional deduction of training expenses or
for the concept of innovation, with respect to taxpayers who begin operations in
the fiscal years 2025 to 2030
11.18.4.
For the purposes of article 11, first and second paragraphs of the Decree to which
this Chapter refers, in the case of those taxpayers who begin operations in the
fiscal years 2025, 2026, 2027, 2028, 2029 and 2030, who opt to apply the fiscal
incentive of the additional deduction of training expenses or for the concept of innovation,
determine the increase in said expenses in accordance with the following:
I.
For the fiscal year in which taxpayers begin operations, who opt
to apply the fiscal incentive of article 11 of the Decree to which this
Chapter refers, the increase will be the corresponding amount of expenses incurred
for the concept of training or innovation in said fiscal year.
II.
For the second fiscal year, the increase will be the positive difference between the
expense incurred for the concept of training or innovation in said fiscal year
and the expense incurred by taxpayers for the same concepts in the
previous fiscal year.
III.
For the third fiscal year, the increase will be the positive difference between the expense incurred for the concept of training or innovation in the fiscal year
corresponding and the average expense incurred by taxpayers for the
same concepts in the two immediately preceding fiscal years.
IV.
From the fourth fiscal year and subsequent years, the increase will be the positive
difference between the expense incurred for the concept of training or innovation in the
corresponding fiscal year and the average expense incurred by the
taxpayers for the same concepts in the three immediately preceding fiscal
years, averaging even if no expense was incurred in said years for those concepts.
Decree PODECIBI DOF 04/07/2025 11
Notice of update of activities and obligations in the RFC for the provision of
digital services
12.1.10.
For the purposes of article 18-B of the IVA Law, taxpayers who are natural persons
residing in Mexico, as well as those residing abroad without a permanent
establishment in national territory who provide the digital services referred to in the
article mentioned, must present the Notice of update of economic
activities and obligations in the RFC, through the presentation of a clarification case
in the SAT Portal, using the label " AVISO ACTUALIZACION 18-B LIVA " , indicating
the following:
I. to IV.
...
LIVA 18-B
Transitory
Tenth
Fourth.
It is repealed.
Twenty-Fifth.
For the purposes of article 36 Bis of the CFF and rule 3.10.1.5., third paragraph, the
civil organizations and trusts authorized to receive deductible donations, to
whom a fine had been imposed for the infringement indicated in article 81,
first paragraph, fraction XLIV of the CFF, may maintain the validity of the authorization referred to in the cited rule for the fiscal year 2026, provided that, no later than September 30
of 2025, they have complied with the following:
I.
File the informational declarations referred to in rule 3.10.1.5., third
paragraph, fraction I, items a) and b), corresponding to the fiscal year 2024.
II.
Have paid the fine indicated in the first paragraph of this provision.
III.
Have not filed any means of defense against the fine referred to, or
well, have withdrawn it.
In the event that, after September 30, 2025, a means of
defense is filed against the fine referred to in the first paragraph of this provision,
the continuity of the validity of the authorization in terms of rule
3.10.1.5., third paragraph, will not proceed, so the provisions of rule
3.10.1.19. " will apply.
SECOND.
Annex 26 of the RMF for 2025 is made known, as well as the modifications of the
following Annexes:
I.
Second Modification to Annex 1 of the RMF for 2025.
II.
Fourth Modification to Annex 1-A of the RMF for 2025.
III.
Second Modification to Annex 14 of the RMF for 2025.
IV.
Eleventh Modification to Annex 15 of the RMF for 2022.
V.
First Modification to Annex 27 of the RMF for 2025.
VI.
First Modification to Annex 29 of the RMF for 2025.
VII.
First Modification to Annex 30 of the RMF for 2025.
VIII.
First Modification to Annex 31 of the RMF for 2025.
IX.
First Modification to Annex 32 of the RMF for 2025.
Transitory
UNIQUE.
This resolution will enter into force from the day following its publication in the
DOF. With respect to the provisions made known in advance in the
SAT Portal, its content will take effect in terms of rule 1.8., third paragraph.
Annex 26 that is made known in this Resolution, will enter into force on January 1
of 2026.
Respectfully.
Mexico City, October 14, 2025.- In substitution for the absence of the Head of the
Tax Administration Service, based on article 4, first paragraph of the Internal Regulations of the
Tax Administration Service, the General Legal Administrator, Lic. Ricardo Carrasco
Varona signs.-
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