Fourth Resolution of Modifications to the General Fiscal Resolution for 2025 and Annex 7

DOF: 09/07/2025

FOURTH Resolution of Modifications to the General Fiscal Resolution for 2025 and Annex 7

At the margin, a seal with the National Coat of Arms, which says: United Mexican States.- Treasury.- Ministry of Finance and Public Credit.- Tax Administration Service.

FOURTH RESOLUTION OF MODIFICATIONS TO THE GENERAL FISCAL RESOLUTION FOR 2025 AND ANNEX 7

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 Tax Administration Service Law and 8 of the Internal Regulations of the Tax Administration Service, resolves:

FIRST. Rule 2.1.6., fraction I, is added, moving the current fractions I and II to become II and III, and Chapter 11.16, which comprises rule 11.16.1., is added to the General Fiscal Resolution for 2025, to read as follows:

"Unworkable Days

2.1.6.

...

I.

The first general vacation period of 2025 comprises the days from July 18 to July 31, 2025.

II.

...

III.

...

...

CFF 12, 13, LA 18, LCF 13, 14

Chapter 11.16. On the Decree granting tax incentives to taxpayers indicated in the matter of fees for migratory services, published in the DOF on June 30, 2025

Concentration and transfer carried out by shipping companies and consignee shipping agents of the fees for the provision of migratory services to foreigners who enter the country via maritime routes

11.16.1.

For the purposes of Article First of the Decree referred to in this Chapter, foreign passengers who enter national territory via maritime routes on board cruise ships may pay the fee referred to in Article 8o., fraction I of the LFD, through shipping companies or consignee shipping agents, who will concentrate the aforementioned payment.

Shipping companies and consignee shipping agents must observe the following:

I.

Request via email soporte.maritimo@inami.gob.mx from INAM a login account for the Maritime Services Portal.

II.

Access the Maritime Services Portal through the Internet page https://www.inm.gob.mx/mserviciom/portal/maritimo/inmex.html to upload the electronic list of crew members and passengers entering the country, in accordance with what is established in Article 46 of the Migration Law, as well as 42, fraction I and 43 of its Regulations, to identify the subjects obligated to pay the fee that must be made.

III.

INAM will validate the information contained in the electronic list and the Maritime Services Portal will automatically calculate the amount of the fee to be paid, regarding each vessel.

Shipping companies, directly or through their consignee shipping agents, must concentrate the fees referred to in this rule no later than the 17th day of the calendar month immediately following the date on which the fee was incurred, at a bank counter or via electronic transfer to the bank account that INAM will make known through the Maritime Services Portal and authorized by TESOFE.

For the purposes of the preceding paragraph, INAM will send via email to each of the shipping companies and/or consignee shipping agents the total amount to be covered and the capture line to make the payment via electronic transfer, requesting confirmation of receipt of the message.

Likewise, shipping companies and/or consignee shipping agents may opt to make the payment at a bank counter or via electronic transfer using the help sheet obtained through the electronic address https://www.inm.gob.mx/gobmx/derechos/ in accordance with the procedure established in rule 2.8.4.1.

The concentration carried out by shipping companies and consignee shipping agents must correspond to the total amount referred to in the preceding paragraph.

Shipping companies and/or consignee shipping agents must send to INAM, through the email DNR_cruceros@inami.gob.mx, within three business days following the date on which the fee concentration was made, the receipt and the list of paid operations, indicating the following:

I.

Name of the shipping company.

II.

Trade name.

III.

Name of the consignee shipping agent, if applicable.

IV.

Name of the vessel.

V.

Number of foreign passengers for whom the payment of the fee referred to in Article 8o., fraction I of the LFD will be made, per vessel.

VI.

Port of arrival for each operation performed.

LFD 8o., Decree DOF 30/06/2025 First, RMF 2.8.4.1. "

SECOND.

The First Modification to Annex 7 of the RMF 2025 is made known.

Transitory

SINGLE. This resolution will enter into force from the day following its publication in the DOF. With respect to the provisions made known in advance on the SAT Portal, their content will take effect in terms of rule 1.8., third paragraph.

Respectfully.

Mexico City, July 2, 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. - Rubric.

FIRST MODIFICATION TO ANNEX 7 OF THE GENERAL FISCAL RESOLUTION FOR 2025

Compilation of fiscal normative criteria

............................................................................................................................................. .

Content

A.

Current:

I.

...

II.

Criteria of the Income Tax Law

1/ISR/N a

............................................................................................................ ..

58/ISR/N

............................................................................................................ ...

59/ISR/IVA/N

Digital Platforms. Compliance with tax obligations of individuals with business activities that provide services through the Internet and technological platforms, computer applications, and similar.

III. to VI. ...

B.

...

A.

Current

I.

...

II.

Criteria of the Income Tax Law

...

59/ISR/IVA/N

Digital Platforms. Compliance with tax obligations of individuals with business activities that provide services through the Internet and technological platforms, computer applications, and similar.

Article 113-A of the Income Tax Law establishes that individuals with business activities that alienate goods or provide services through the Internet, via technological platforms, computer applications, and similar that provide the services referred to in Article 18-B, fraction II of the Value-Added Tax Law, are obligated to pay income tax in terms of Title IV, Chapter II, Section III of the Income Tax Law, for the income they generate through said means.

On the other hand, Article 18-K of the Value-Added Tax Law states that what is provided in the aforementioned Law shall apply to individuals and legal entities that carry out activities subject to the payment of VAT, through residents abroad without a permanent establishment in Mexico, who provide intermediary services between third parties who are providers of services and those who demand them, that is, they are obligated to pay the tax for said activities in terms of the aforementioned Law.

Now, through the reform to the Federal Labor Law, contained in the "Decree by which various provisions of the Federal Labor Law are added, in the matter of Digital Platforms", published in the DOF on December 24, 2024, Chapter IX Bis, titled "Work on Digital Platforms", was added to said Law, with the intention of recognizing and safeguarding the labor and social security rights of the workers of the aforementioned platforms, so that they are treated equitably with respect to other persons who work according to traditional schemes.

In the statement of motives of the aforementioned reform to the labor legislation, the nature of the work carried out through digital platforms was taken into consideration, conceiving it as a labor relationship different from the most traditional labor schemes, due to the dynamics and modality of its realization, which will only exist during the time effectively worked by the worker, which will be defined by the latter, so that the work carried out in this modality will be flexible and discontinuous. Thus, although the legislator grants the character of a subordinate labor relationship, due to the particularities of the work scheme on digital platforms, a traditional labor relationship is not configured.

In this sense, understanding the social reasons for the reform to the Federal Labor Law, it is considered that in fiscal matters, the nature and elements proper to the economic activity that gives rise to the generation of income or consideration of the individuals who carry it out through said technological platforms must be addressed.

Thus, in fiscal matters, in accordance with what is established in Article 113-A of the Income Tax Law, those who provide services through the Internet via technological platforms, computer applications, and similar, carry out a business activity, by alienating goods or providing an independent personal service, so that the income derived from said activity could not have the fiscal treatment corresponding to the income received for the provision of a subordinate personal service, referred to in Title IV, Chapter I of the Income Tax Law.

Likewise, for the purposes of what is established in Chapters I and III Bis of the Value-Added Tax Law, the acts or activities carried out by individuals through technological platforms and the consideration received for them, will have the fiscal treatment that regulate the aforementioned Chapters, because the nature of the same is not modified.

In these considerations, for fiscal purposes, individuals who provide services through the Internet, via technological platforms, computer applications, and similar, who are considered workers of said platforms due to the entry into force of the "Decree by which various provisions of the Federal Labor Law are added, in the matter of Digital Platforms", as well as the aforementioned technological platforms, computer applications, and similar, will continue to comply with their tax obligations applying what is established in Title IV, Chapter II, Section III of the Income Tax Law and in Chapters I and III Bis of the Value-Added Tax Law, for the income and consideration they obtain through said means.

III. to VI.

...

B.

...

Respectfully.

Mexico City, July 2, 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. - Rubric.

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