Resolution of Administrative Facilitations for Taxpayers in the Sectors Identified Therein for 2025

DOF: 17/02/2025

RESOLUTION of administrative facilitations for taxpayers in the sectors identified therein for 2025

A seal with the National Coat of Arms appears at the margin, stating: United Mexican States.- Treasury.- Ministry of Treasury and Public Credit.- Tax Administration Service.

RESOLUTION OF ADMINISTRATIVE FACILITATIONS FOR TAXPAYERS IN THE SECTORS IDENTIFIED THEREIN FOR 2025

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 Fiscal Code; 14, fraction III of the Tax Administration Service Law; 8 of the Internal Regulations of the Tax Administration Service and 77 of the Regulations of the Value Added Tax Law, and

Considering

That the Income Tax Law establishes cash-basis regimes applicable to taxpayers in the primary and land freight and passenger transport sectors;

That the Tax Administration Service, based on the powers conferred upon it by the Congress of the Union to establish rules of a general nature, considers it necessary to grant, for the 2025 fiscal year, to the aforementioned taxpayers, administrative and verification facilitations, in order to simplify the compliance of their tax obligations. Likewise, during the 2025 fiscal year, it will continue to publish brochures and hold workshops, with the objective that these taxpayers, through practical examples and precise situations, can learn about their tax obligations and how to comply with them;

That this decentralized body, through its orientation services, will inform and resolve the doubts raised by taxpayers in the sectors referred to in this Resolution, in accordance with the development of their activities, so that they can adequately comply with their tax obligations, and

That the attention to the operational characteristics of said taxpayers requires this body to issue the following:

RESOLUTION OF ADMINISTRATIVE FACILITATIONS FOR TAXPAYERS IN THE SECTORS IDENTIFIED THEREIN FOR 2025

Content

Title 1. Primary Sector.

Title 2. Federal Land Freight Transport Sector.

Title 3. Interstate Land Passenger and Tourism Transport Sector.

Title 4. Land Freight Transport of Materials and Urban and Suburban Land Passenger Transport Sector.

Glossary

For the purposes of this Resolution, the following are understood:

CFDI, the Digital Fiscal Receipt via Internet or Electronic Invoice.

CFF, the Federal Fiscal Code.

CURP, the Unique Population Registry Key of 18 positions.

DOF, the Official Gazette of the Federation.

IMSS, the Mexican Institute of Social Security.

ISR, the income tax.

IVA, the value added tax.

LIF, the Federal Revenue Law for the Fiscal Year 2025.

RFC, the Federal Taxpayer Registry.

RMF, the Fiscal Miscellany Resolution for 2025.

SAT, the Tax Administration Service.

UMA, the Measurement and Update Unit.

Preliminary Provision

This Resolution contains the administrative and verification facilitations applicable to taxpayers in each of the sectors identified in the Titles thereof for the 2025 fiscal year.

Title 1. Primary Sector

Definition of livestock activities

1.1. For the purposes of articles 74 and 113-E, ninth and tenth paragraphs of the Income Tax Law, as applicable, taxpayers dedicated exclusively to livestock activities will consider as such those consisting in the breeding and fattening of cattle, poultry and animals, as well as the first alienation of their products that have not been subject to industrial transformation.

The acquisition of the first alienation of livestock referred to in the previous paragraph will also be considered a livestock activity, when the acquirers carry out exclusively cattle fattening activities, provided that the fattening process is carried out in a period greater than three months counted from the acquisition.

The provisions of this rule will in no case be applicable to taxpayers who are not owners of the cattle, poultry and animals referred to therein.

Verification facilitations

1.2. For the purposes of the Income Tax Law, taxpayers dedicated exclusively to agricultural, forestry, livestock or fishing activities, who comply with their tax obligations under the terms of article 74 of the Income Tax Law, may deduct the sum of the expenditures they incur for the concept of labor of occasional field workers, livestock feed and minor expenses, up to 10 percent of their total own income, without exceeding $800,000.00 (eight hundred thousand pesos 00/100 M.N.) during the fiscal year, provided that they comply, at least, with the following:

I. That the expense has been effectively incurred in the fiscal year in question and is linked to the activity.

II. That it has been recorded in their accounting by concept and in an accumulative manner during the fiscal year.

III. That the expenses are supported with documentation containing at least the following information:

a) Name, denomination or corporate name and address of the seller of the goods, the service provider or the occasional field worker.

b) Place and date of issuance.

c) Quantity and class of merchandise, description of the service or type of occasional work.

d) Unit value stated in numbers and total amount stated in numbers or letters.

In the event that the sum of the expenditures exceeds the percentage or amount cited in the first paragraph of this rule, the amount that can be deducted in accordance with this provision will be determined by maintaining the same percentage structure of each of them.

Each of the minor expenses referred to in the first paragraph of this rule may not exceed $5,000.00 (five thousand pesos 00/100 M.N.).

To determine the total amount of minor expenses subject to the verification facilitation referred to in this rule, the proportion that these expenses represent in the fiscal year in question, with respect to the sum of the total of their expenditures for the concept of labor of occasional field workers, livestock feed and minor expenses, of the same fiscal year, must be considered, provided that this proportion is not greater than that determined in accordance with this rule for the immediately preceding fiscal year. In the event that the proportion of the fiscal year in question turns out to be greater, the proportion of the immediately preceding fiscal year will be considered.

To the total amount of minor expenses determined in accordance with the previous paragraph, the factor resulting from subtracting from unity the lesser proportion referred to in the previous paragraph will be applied. The result obtained will be the maximum amount of minor expenses that can be deducted under the terms of this rule.

The amount of the deduction determined in accordance with the present rule, in the fiscal year in question, must be reduced by the amount obtained by subtracting from the total of the taxable income obtained in the year, the deductions authorized in accordance with the Income Tax Law, for which the facilitations referred to in this Resolution do not apply, and up to the amount of the difference resulting from reducing the total amount of taxable income obtained in the year, the deductions authorized in accordance with the Income Tax Law for which the facilitations referred to in this Resolution do not apply.

When the deductions authorized in accordance with the Income Tax Law for which the facilitations referred to in this Resolution do not apply, are greater than the taxable income obtained in the year, no amount will be reduced for the concept of the deduction referred to in this rule.

Moral persons taxpayers must report in the annual income tax return, the amount of the deduction corresponding, in the field "Administrative facilitations and deductible incentives" in the options "Deduction of minor expenses without fiscal requirements" and "Deduction of labor of occasional field workers and livestock feed".

The deduction provided for in the first paragraph of this rule will not include expenses incurred by taxpayers for the acquisition of fuels to carry out their activity.

Semi-annual provisional payments of the 2025 fiscal year

1.3. For the purposes of article 74 of the Income Tax Law, taxpayers who must comply with their tax obligations in accordance with the regime established in Title II, Chapter VIII of the aforementioned legislation, may opt to make semi-annual provisional payments of the income tax, provided that the withholdings of this tax that they make to third parties and the corresponding VAT declarations, they pay and present within the same deadlines in which they make their provisional payments of the income tax.

Moral persons that for the 2025 fiscal year opt to make provisional payments and effect the payment of the income tax withheld to third parties, as well as the presentation of the corresponding VAT declaration in a semi-annual manner, must present the notice of update of economic activities and tax obligations before the tax authorities, within thirty days following the entry into force of this Resolution, in terms of what is established in article 30, fraction V of the Regulations of the Federal Fiscal Code and in the procedure form 71/CFF "Notice of update of economic activities and obligations", contained in Annex 1-A of the RMF. Taxpayers who for previous exercises had already presented the notice of option to present their provisional payments related to the income tax and VAT in a semi-annual manner, will not have to present the corresponding notice until such time as they change the option chosen.

Moral persons to determine the provisional payments of the income tax of the 2025 fiscal year, instead of applying what is established in article 74 of the Income Tax Law, may determine them by applying to the taxable income of the period in question, the profit coefficient that corresponds in terms of article 14 of the aforementioned Law, considering the total of their income. Once the option referred to in this rule has been exercised, it cannot be varied during the fiscal year in question.

Withholding of income tax for occasional field workers

1.4. Taxpayers dedicated exclusively to agricultural, forestry, livestock or fishing activities, who comply with their tax obligations in terms of articles 74 and 113-E, ninth and tenth paragraphs of the Income Tax Law, as applicable, for the purposes of complying with the obligations established in the tax provisions regarding withholdings of income tax for payments made to their occasional field workers, instead of applying the corresponding provisions for the payment of salaries, may pay 4 percent for the concept of income tax withholdings, corresponding to the payments effectively made for the concept of labor, provided that the payments made to each occasional field worker do not exceed $840.00 (eight hundred forty pesos 00/100 M.N.) per day in the geographic area of the Free Zone of the Northern Border defined in accordance with the Resolutive First of the Resolution of the Honorable Council of Representatives of the National Commission of Minimum Wages that fixes the general and professional minimum wages that will govern from January 1, 2025, published in the DOF on December 19, 2024, and $558.00 (five hundred fifty-eight pesos 00/100 M.N.) in the rest of the country, in which case, they must prepare and present by February 15, 2026 at the latest, a notice containing an individualized list of said workers indicating the amounts paid to them in the previous year, as well as the tax withheld, in terms of procedure form 92/ISR "Notice presented by taxpayers dedicated to agricultural, livestock or fishing activities who exercise the option to pay 4 percent for the concept of income tax withholdings" contained in Annex 1-A of the RMF; in addition, they must issue the CFDI and its complement for the concept of payroll corresponding.

The taxpayers referred to in this rule, whose occasional field workers have adhered to the "Decree by which fiscal benefits are granted to employers and occasional field workers", published in the DOF on July 24, 2007 and modified through those published in the same official gazette on January 24 and December 30, 2008; December 28, 2010; December 20, 2012; December 30, 2013; December 29, 2014; December 29, 2016; December 31, 2018; December 30, 2020; December 20, 2022 and December 26, 2024, instead of applying what is established in the first paragraph of this rule, may consider the base salary for affiliation that they declare to pay the employer-employee quotas to the IMSS in terms of the aforementioned Decree for the 2025 fiscal year, to determine the withholding referred to in the previous paragraph.

With respect to payments made to workers other than those indicated in this rule, the provisions of the Income Tax Law will apply.

Distributor settlements

1.5. When taxpayers dedicated exclusively to agricultural, forestry, livestock or fishing activities, who comply with their tax obligations in terms of article 74 of the Income Tax Law, operate through distributors resident abroad without a permanent establishment in Mexico or credit unions in the country, the settlements obtained from said distributors will serve as sales receipts, provided that the latter issue the fiscal receipt or the corresponding CFDI, as applicable. The producer on whose behalf the distributor carries out the corresponding operations must keep a copy of the settlement as part of their accounting.

When such settlement consigns expenses incurred by the distributor, on behalf of the taxpayer, it will serve as a fiscal receipt for such expenditures, provided that they are considered as deductions and comply with the deductibility requirements, established in the applicable tax provisions for such expenditures.

The only expenses that will be deductible in accordance with this paragraph are those consigned in said settlement.

In settlements issued by distributors resident abroad, in substitution of the data related to the RFC, the data corresponding to the name, denomination or corporate name, tax address and, if applicable, tax identification number must be consigned.

When the distributor resident in national territory incurs expenses on behalf of the taxpayer, they may issue the CFDI with the key in the RFC of this, in order for them to be considered as deductions, provided that they comply with the requirements established in the applicable tax provisions for such expenditures; when opting for what is established in this paragraph, the only expenses that will be deductible are those that appear in said CFDI. Regarding payments made abroad, the receipts must meet the requirements indicated in rule 2.7.1.14. of the RMF.

Obligations of moral persons of agrarian law exempt from income tax

1.6. For the purposes of article 74 of the Income Tax Law, regarding moral persons of agrarian law that must comply with their tax obligations in accordance with the regime established in Title II, Chapter VIII of the aforementioned legislation, whose income in the fiscal year does not exceed 20 times the annual value of the UMA for each of their members, without exceeding collectively 200 times the annual value of the UMA, will not be obligated to present provisional or annual income tax payment declarations for the income from their activity, including information declarations for which no payment is made, as well as those corresponding to VAT. Regarding ejidos and communities, the limit of 200 times the annual value of the UMA will not be applicable.

The facilitation referred to in the previous paragraph will not be applicable to taxpayers whose income exceeds the limits indicated, so they must present all the corresponding declarations for the exercise in question.

Option of facilitations for moral persons that do not carry out activities on behalf of their members

1.7. Moral persons dedicated exclusively to agricultural, forestry, livestock or fishing activities, that do not carry out business activities on behalf of their members, may apply the facilitations referred to in the previous rules, provided that they pay taxes in the Regime of Agricultural, Livestock, Forestry and Fishing Activities referred to in Title II, Chapter VIII of the Income Tax Law.

No obligation to pay by nominative check, cards or electronic wallets

1.8. Natural or moral persons who make payments to taxpayers dedicated exclusively to agricultural, forestry, livestock or fishing activities, whose amount does not exceed $5,000.00 (five thousand pesos 00/100 M.N.) to the same person in the same calendar month, will be exempt from the obligation to pay them with a nominative check of the taxpayer; credit, debit or service card; or through electronic wallets authorized for this purpose by the SAT.

Acquisition of fuels

1.9. Taxpayers dedicated exclusively to agricultural, forestry, livestock or fishing activities, who comply with their tax obligations in terms of articles 74 and 113-E, ninth and tenth paragraphs of the Income Tax Law, will consider the obligation established in article 27, fraction III, second paragraph of the Income Tax Law fulfilled, when payments for fuel consumption are made with means other than a nominative check from the taxpayer's account; credit, debit or service card; or electronic wallets authorized by the SAT, provided that these do not exceed 15 percent of the total payments made for fuel consumption to carry out their activity. In addition, the fiscal receipt must contain the information of the valid permit, issued in accordance with the Hydrocarbons Law to the fuel provider and that, if applicable, said permit is not suspended at the time of issuance of the fiscal receipt.

Value added tax

1.10. For the purposes of article 75 of the Income Tax Law, moral persons dedicated exclusively to agricultural, livestock, forestry or fishing activities, who comply with their obligations in terms of article 74 of the aforementioned law, may comply with tax obligations in matters of VAT on behalf of each of their members, applying what is established in the VAT Law.

In addition, they must issue the settlement to their members through a CFDI of withholdings and payment information, with the following requirements:

I. Denomination or corporate name, tax address and RFC key of the moral person, as well as the consecutive folio number.

II. Place and date of issuance.

III. Name of the member to whom it is issued, their RFC key or, if applicable, the CURP, location of their business or address and signature of the same or of who receives the document.

IV. Global description of the concepts of income, deductions and, if applicable, taxes and withholdings corresponding to the member in question.

The moral persons referred to in this rule must issue the CFDI of withholdings and payment information, to which the "Settlement Complement", published in the SAT Portal for this purpose, must be incorporated. In said CFDI, in addition, they must record the information corresponding to the value of activities, the VAT transferred, the VAT transferred to them, as well as, if applicable, the paid in importation.

Moral persons who comply with tax obligations on behalf of their members, will present the corresponding VAT declarations globally for their operations and those of their members, for the business activities carried out through the moral person.

Income of the moral person

1.11. In terms of article 74, thirteenth paragraph of the Income Tax Law, societies or associations of producers, as well as other moral persons, that are dedicated exclusively to agricultural, livestock, forestry or fishing activities, constituted exclusively by natural person partners or associates, and that the income of the moral person in the year, per partner, does not exceed 423 times the annual value of the UMA, without exceeding in its entirety 4,230 times the annual value of the UMA, may reduce the tax determined in accordance with the aforementioned article 74, by 30 percent.

Information with VAT suppliers

1.12. For the purposes of article 32, fraction VIII of the VAT Law, taxpayers who opt to apply what is established in rule 1.3. of this Resolution, must present the information referred to in said fraction, in the same deadlines in which they make the provisional payments of the income tax. Regarding moral persons referred to in article 74 of the Income Tax Law, who comply with tax obligations on behalf of their members, they will present the information referred to in this rule globally for their operations and those of their members, in relation to the business activities carried out through the moral person.

Credit of fiscal incentives

1.13. Taxpayers dedicated exclusively to agricultural, forestry, livestock or fishing activities, who comply with their tax obligations in terms of article 74 of the Income Tax Law, and who obtain in the fiscal year total annual income for income tax purposes less than 60 million pesos, may effect the credit of the fiscal incentive that corresponds to them in accordance with what is established in article 16, section A, fraction II, last paragraph of the LIF, against the own income tax caused in the year in which fuel is imported or acquired, or against the income tax withholdings made to third parties in the same year.

The aforementioned taxpayers may opt to apply the credit of the aforementioned fiscal incentive against the provisional payments of the income tax of the year, provided that the amount of the aforementioned fiscal incentive that they have credited in said provisional payments, they do not consider it as part of the provisional payments that they credit in the declaration of

exercise. The administrative facilities referred to in this rule shall not apply to taxpayers who request the refund referred to in Article 16, Section A, Fraction III of the LIF.

Taxpayers must consider as taxable income for ISR purposes the incentive referred to in this rule at the moment they effectively credit it.

For the purposes of Article 16, Section A, Fraction I, first paragraph of the LIF, in the event that the total annual income obtained by the taxpayers referred to in the first paragraph of this rule reaches or exceeds 60 million pesos, at any time during the exercise, the crediting of the fiscal incentive referred to in this rule shall cease to apply from the beginning of the exercise. In this case, they must file complementary declarations for previous months and, if applicable, pay the difference of the unpaid tax with its respective update and surcharges. The resulting tax shall be updated for the period from the month in which the declaration in which the fiscal incentive was applied was filed, until the month in which the corresponding payment is made, in accordance with Article 17-A of the CFF; furthermore, the taxpayer must pay surcharges for the same period in accordance with Article 21 of the cited Code.

Taxpayers who begin activities may apply what is established in the first and second paragraphs of this rule, when they estimate that their total annual income for the exercise will not exceed the amount established in Article 16, Section A, Fraction I, first paragraph of the LIF. If in the initial exercise they carry out operations for a period of less than twelve months, to determine the cited amount, they will divide the income obtained by the number of days comprising the period and multiply the result by 365 days. If the amount obtained is equal to or exceeds the referred amount, the facility of the first and second paragraphs of this rule shall cease to apply from the beginning of the exercise and the provisions of the fourth paragraph thereof shall apply.

Notice of application of the fiscal incentive

1.14.

For the purposes of Article 25 of the CFF and rule 1.13. of this Resolution, taxpayers who apply the fiscal incentives established in Article 16, Section A, Fractions I and II, numeral 2 of the LIF, shall only present the notice referred to in the cited Article 25, when they apply said incentive for the first time in the declaration of provisional payment, definitive payment or in the annual declaration, as applicable, within fifteen days following the presentation of the first declaration in which the incentive is applied, in accordance with the procedure form 4/LIF "Notice by which a fiscal incentive is granted to persons who carry out business activities and who, to determine their profit, may deduct diesel or biodiesel and their mixtures that they acquire or import for final consumption, provided that they are used exclusively as fuel in general machinery", contained in Annex 1-A of the RMF.

Notice of partners, shareholders, associates and others

1.15.

For the purposes of Article 27, Sections A, Fraction II and B, Fraction VI of the CFF, legal entities dedicated exclusively to agricultural, livestock, forestry or fishing activities, which comply with their tax obligations in accordance with Article 74 of the ISR Law, shall be exempt from presenting the notice to the RFC in which they inform the name and RFC key of the partners, shareholders, associates and other persons, regardless of the name by which they are designated, who hold such status in accordance with their statutes or legislation under which they are constituted, except when the tax authority requires its presentation.

Option for partners or members of fishing or forestry production cooperatives

1.16.

Natural persons who are partners of production cooperatives dedicated exclusively to fishing or forestry activities that have a concession or permit from the Federal Government to exploit marine or forestry resources, may opt for the exemption of $900,000.00 (nine hundred thousand pesos 00/100 M.N.) referred to in Article 113-E, ninth paragraph of the ISR Law, through said cooperatives, considering for said amount the total of the income they receive from the cited activities effectively collected in the exercise, provided that all partners of the cooperative in question exercise the referred option and said cooperatives comply with the following requirements:

I.

They are composed exclusively of natural persons.

II.

They do not apply the exemption established in Article 74, eleventh paragraph of the ISR Law, for each of their partners.

III.

They calculate and pay the ISR corresponding to the returns and advances that are distributed in the fiscal year in accordance with what is established in Articles 94 and 96 of the ISR Law, for the income that exceeds $900,000.00 (nine hundred thousand pesos 00/100 M.N.) for each of their partners.

IV.

They present by July 1, 2025 at the latest, the updated list of partners, entering the SAT Portal, and complete the form in accordance with procedure form 295/CFF "Request for modification or incorporation of partners, shareholders, associates and other persons who are part of the organizational structure of a legal entity, as well as those who have control, significant influence, command power and legal representatives", contained in Annex 1-A of the RMF.

In the event that during the fiscal year, the society registers changes in the information of its partners, it must carry out the corresponding update through the procedure described in the previous paragraph, within thirty business days following the one in which the modification or incorporation of partners took place, if not, it will be understood that the cooperative society and its partners cease to apply what is established in this rule and must be, once the referred period has passed, subject to what is stated in Article 74 of the ISR Law and other applicable provisions.

V.

Provide through the SAT Portal, in "My Portal" through a case of "Service or requests", selecting the option "SOC COOP PES O SILVI INGRESOS", an Excel file (*XLSX) containing a monthly accumulated report of the income received by each partner in each of the months of the exercise. Said report shall be presented, by the 17th day of the month immediately following that to which the income corresponds.

Title 2. Federal Land Freight Transport Sector

Withholding of ISR on operators, macheteros and maneuverers

2.1.

Taxpayers, natural and legal persons, dedicated exclusively to federal land freight transport and who pay tax in accordance with Title II, Chapter VII or Title IV, Chapter II, Section I of the ISR Law, may opt to pay 7.5 percent for the concept of ISR withholdings, corresponding to payments effectively made to operators, macheteros and maneuverers, instead of applying the corresponding provisions for the payment of salaries.

To calculate these withholdings, the base salary used for the calculation of contributions by said workers to the IMSS shall be taken as reference, in accordance with applicable regulations, in which case, they must prepare and deliver, by February 15, 2026 at the latest, an individualized list of said personnel in which the amounts paid to them in the period in question are indicated, in the terms in which it is prepared for the purposes of the contributions they make to the IMSS, as well as the withheld tax, in accordance with procedure form 91/ISR "Notice presented by taxpayers dedicated to the activity of federal land freight transport who exercise the option to pay 7.5 percent for the concept of ISR withholdings", contained in Annex 1-A of the RMF, in addition to issuing the CFDI and its complement for payroll purposes corresponding.

Regarding payments made to workers other than those indicated in this rule, what is established in the ISR Law shall apply.

This rule shall be applicable provided that the taxpayers referred to in the first paragraph thereof do not predominantly provide their services to another legal entity resident in the country or abroad, which is considered a related party in the terms of the ISR Law.

Verification facilities

2.2.

For the purposes of the ISR Law, natural or legal person taxpayers, dedicated exclusively to federal land freight transport and who pay tax in accordance with Title II, Chapter VII or Title IV, Chapter II, Section I of the ISR Law, may deduct up to the equivalent of 8 percent of the income from their activity, without exceeding $1,000,000.00 (one million pesos 00/100 M.N.) during the exercise, without the need to have documentation that meets fiscal requirements, provided that:

I.

The expense has been effectively incurred in the corresponding fiscal year and is directly linked to the taxpayer's activity.

II.

The expenditure for which the facility is applied is registered in the taxpayer's accounting by concept and in an accumulated manner during the fiscal year.

III.

The taxpayer pays the annual ISR on the amount deducted in accordance with this rule, applying a rate of 16 percent. The annual tax paid on said amount shall be considered definitive and shall not be creditable or deductible for tax purposes. In the case of coordinators or legal entities that pay tax on behalf of their members, they must make the payment of said tax on behalf of the same.

IV.

Taxpayers who opt for the facility referred to in this rule must make provisional payments on account of the annual tax referred to in the previous fraction. These payments shall be determined considering the deduction made in the accumulated payment period of the fiscal year in question, applying a rate of 16 percent. In addition, they may credit provisional payments made previously in the same fiscal year for the same concept. These provisional payments must be paid through the ISR declarations for natural persons, business and professional activity or for legal persons ISR, coordinator regime, own tax or of their members, by the 17th day of the month following that for which the deduction is made, or that corresponding in accordance with Article 5.1 of the "Decree that compiles various fiscal benefits and establishes measures of administrative simplification", published in the DOF on December 26, 2013.

The deductible amount determined in accordance with the present rule in the exercise in question, must be subtracted from the difference between the taxable income obtained in said exercise and the deductions authorized in accordance with the ISR Law for which the facilities referred to in this Resolution do not apply and up to the amount of said difference.

In the event that the deductions authorized in accordance with the ISR Law for which the facilities of this Resolution do not apply are greater than the taxable income obtained in the exercise, no amount shall be reduced for the concept of the deduction referred to in this rule.

The taxpayers mentioned in the first paragraph of this rule must inform in the annual ISR declaration, the amount corresponding to the deduction, indicating it in the field "Administrative facilities and deductible incentives" within the option "Deduction equivalent to up to 8% of own income without documentation that meets fiscal requirements for taxpayers dedicated exclusively to freight transport".

What is established in this rule shall not apply to expenses incurred by taxpayers for the acquisition of fuels to carry out their activity.

Joint liability of coordinators

2.3.

Coordinators who opt to apply the facilities established in rules 2.1. and 2.2. of this Resolution, in the event that their members opt to pay tax individually, shall be jointly liable only for the income, deductions, taxes and withholdings that they have recorded in the settlement issued to the member in question. Said coordinators must annually provide the tax authority with detailed information on the income, deductions, taxes and withholdings that they have recorded in the cited settlement corresponding to each of their members who have opted to pay tax individually.

Master accounts

2.4.

Natural persons with permits for federal land freight transport who constitute transport companies, may open and use for making the corresponding expenditures for the activities of said companies, dynamic or business master accounts in the name of any of the natural person permit holders who are members of the legal entity in question, provided that the movements made in said accounts agree with the accounting records of the company and with the settlement issued for such effect to the natural person permit holders.

Concept of coordinator

2.5.

For the purposes of what is established in Articles 72 and 73 of the ISR Law, a coordinator shall be considered as any legal entity dedicated exclusively to the service of federal land freight transport, which groups and integrates with other similar and complementary natural and legal persons, constituted for the purpose of providing necessary services for the common activity of federal land freight transport. These elements integrate an economic unit with common interests and participate jointly and in unidentifiable proportions with the following purposes:

I.

Coordinate and agree on the services provided jointly, including companies that provide services or own real estate dedicated to the activity of federal land freight transport. In the case of terminals or bus stations for freight transport that are not members of any coordinator, they may pay tax in Title II, Chapter VII of the ISR Law, provided that they are composed of companies dedicated to federal freight transport and provide their services predominantly to federal land freight transport companies. In addition, said terminals or bus stations shall not apply the facilities contained in rules 2.1., 2.2. and 2.9. of this Resolution.

II.

Comply with tax obligations on behalf of each of their members globally.

III.

Have a policy manual for the application of common expenses and their proration to each of their members, which they must have available to the tax authorities when requested.

Donations to decentralized public bodies of the Federal Government

2.6.

For the purposes of the ISR Law, natural or legal person taxpayers, dedicated exclusively to federal land freight transport and who pay tax in accordance with Title II, Chapter VII or Title IV, Chapter II, Section I of the ISR Law, may consider as deductible for the purposes of said tax, donations made to decentralized public bodies of the Federal Government, provided that they comply with the requirements established by said Law and that they are projects destined exclusively to productive investments and the creation of infrastructure, to operate in the activity of federal freight transport.

Alienation of shares issued by companies dedicated to land freight transport

2.7.

In the case of the alienation of shares issued by legal entities dedicated to the activity of federal land freight transport, which pay tax in the Coordinator Regime of Title II, Chapter VII of the ISR Law, that are alienated by persons dedicated exclusively to the activity of federal land freight transport, the acquirer of the same is relieved of the obligation to make the 20 percent withholding established in Article 126, fourth paragraph of the ISR Law, provided that the seller of the shares accumulates to the own income of the federal land freight transport activity, the profit determined by said alienation, in the terms of Articles 22, 23, 72, fourth paragraph and 126 of the cited Law.

For the purposes of the previous paragraph, the member of the coordinator who carries out the alienation of the shares, or in its case, the coordinator through which this complies with its tax obligations, must present a report on the alienation of shares prepared by a registered public accountant, in accordance with what is established in rule 2.10.1. of the RMF.

Notice of option to pay tax through a coordinator

2.8.

For the purposes of Article 72, Fraction II, fourth paragraph of the ISR Law, those who opt to pay the ISR through one or more coordinators of federal land freight transport, of which they are members, must present, in addition to the option notice, the notice of update of economic activities and obligations before the tax authorities and inform in writing to the coordinator of which they are members, that they will exercise said option and that they have presented the update notice before the RFC. This procedure must be carried out within thirty days following the entry into force of this Resolution, in accordance with Article 30, Fraction V of the CFF Regulations and procedure form 71/CFF "Notice of update of economic activities and obligations", contained in Annex 1-A of the RMF.

In the case of taxpayers who in previous exercises have presented the option notice to pay tax through a coordinator and the notice of update of economic activities and obligations, referred to in this rule, it will not be necessary to present the corresponding notice again, unless they modify their activities, change the chosen option or have the right to change it in the terms of the ISR Law itself.

Acquisition of fuels

2.9.

Natural or legal person taxpayers, dedicated exclusively to federal land freight transport, who pay tax in accordance with Title II, Chapter VII or Title IV, Chapter II, Section I of the ISR Law, will consider the obligation established in Article 27, Fraction III, second paragraph of the ISR Law fulfilled, when payments for fuel consumption are made with means other than the taxpayer's named check; credit, debit or service card; or electronic wallets authorized by the SAT, provided that these do not exceed 15 percent of the total payments made for fuel consumption to carry out their activity. In addition, the fiscal receipt must contain the information of the valid permit, issued in accordance with the Hydrocarbons Law to the fuel supplier and that, if applicable, said permit is not suspended at the time of issuance of the fiscal receipt.

Value Added Tax

2.10.

For the purposes of Article 72 of the ISR Law, coordinators who comply with their obligations in accordance with Title II, Chapter VII of the cited law, may comply with tax obligations in matters of VAT on behalf of each of their members, applying what is established in the VAT Law.

In addition, they must issue the settlement to their members through a CFDI of withholdings and payment information, with the following requirements:

I.

Name or corporate name, tax address and RFC key, of the legal entity, as well as the consecutive folio number.

II.

Place and date of issuance.

III.

Name of the member to whom it is issued, their RFC key or, if applicable, the CURP, location of their business or address and signature thereof or of the person receiving the document.

IV.

Global description of the concepts of income, deductions and, if applicable, taxes and withholdings, corresponding to the member in question.

Coordinators must issue the CFDI of withholdings and payment information, to which the "Settlement Complement" published on the SAT Portal must be incorporated. In said CFDI, in addition, they must record the information corresponding to the value of activities, the VAT transferred, the VAT transferred to them, as well as, if applicable, the paid in importation.

For the purposes of this rule, those who opt to pay VAT through one or more coordinators of federal land freight transport of which they are members, must manifest to the RFC in their registration or notice of update of economic activities and obligations that they will carry out their activities "As members of a Coordinator that will pay its taxes" and will inform in writing to the coordinator of which they are members about the exercise of said option, indicating the folio and date of the procedure presented before the tax authority.

For the purposes of what is established in the previous paragraph, taxpayers registered in the RFC as of the date of entry into force of this rule will have thirty days following said date to present their notice of update of economic activities and obligations in accordance with what is established in Article 30, Fraction V of the CFF Regulations and in procedure form 71/CFF "Notice of update of economic activities and obligations", contained in Annex 1-A of the RMF, as well as to inform the coordinator of which they are members about the exercise of said option.

Coordinators dedicated to federal land freight transport who comply with tax obligations on behalf of their members, will present the corresponding VAT declarations globally for their operations and those of their members, for the business activities carried out through the coordinator.

Information with VAT suppliers

2.11.

For the purposes of Article 32, Fraction VIII of the VAT Law, coordinators of federal land freight transport who comply with tax obligations on behalf of their members, will present the information referred to in said fraction, globally for their operations and those of their members, in relation to the business activities carried out through the coordinator.

Crediting of fiscal incentives

2.12.

Natural or legal person taxpayers, dedicated exclusively to federal land freight transport and who pay tax in accordance with Title II, Chapter VII or Title IV,

Chapter II, Section I of the Income Tax Law (ISR), taxpayers may credit the tax incentive corresponding to them in accordance with Article 16, Section A, Fraction IV, third paragraph of the Income Tax Law (LIF), against the ISR incurred in the same fiscal year in which the fuel is imported or acquired; against the provisional payments referred to in Rule 2.2, Fraction IV; against the annual ISR referred to in Fraction III of said Rule 2.2 of this Resolution, or against the ISR withholdings made to third parties in the same fiscal year.

Taxpayers referred to in the preceding paragraph, who obtain total annual income for ISR purposes of less than 300 million pesos, in accordance with Article 16, Section A, Fraction V, second paragraph of the LIF, may credit the tax incentive referred to in said provision against the ISR incurred in the same fiscal year in which expenses for the use of toll road infrastructure are incurred; against the provisional payments referred to in Rule 2.2, Fraction IV, or against the annual ISR referred to in Fraction III of said Rule 2.2 of this Resolution.

Taxpayers referred to in this rule may opt to apply the credit of the aforementioned incentives against the provisional ISR payments of the fiscal year, calculated in accordance with the provisions of the relevant Law, provided that the amounts of the aforementioned tax incentives that they have credited in said provisional payments are not considered as part of the provisional payments they credit in the annual return.

The credit of the aforementioned incentives may be applied against the provisional payments for the annual ISR referred to in Rule 2.2, Fraction III of this Resolution, calculated in accordance with the provisions of Fraction IV of the same provision, provided that the amounts of the aforementioned tax incentives that they have credited against said provisional payments are not considered as part of the provisional payments they credit in the said annual ISR return.

Taxpayers must consider as taxable income for ISR purposes the incentives referred to in this rule at the moment they effectively credit them.

For the purposes of the tax incentive established in Article 16, Section A, Fraction V, first paragraph of the LIF, when the total annual income obtained by the taxpayers referred to in the second paragraph of this present rule reaches or exceeds 300 million pesos at any time during the fiscal year, they shall cease to apply the credit of the tax incentive from the beginning of the fiscal year; therefore, they must file complementary returns for previous months and, if applicable, pay the difference of the uncovered tax, updated for the period from the month in which the return in which the tax incentive was applied was filed, until the month in which the corresponding payment is made, in accordance with Article 17-A of the Federal Tax Code (CFF). Additionally, the taxpayer must pay surcharges for the same period in accordance with Article 21 of the cited Code.

Taxpayers who begin activities may apply what is established in the third paragraph of this rule, regarding the tax incentive referred to in Article 16, Section A, Fraction V, first paragraph of the LIF, when they estimate that their total income for the fiscal year will not exceed the amount established in the cited provision. When they carry out operations for a period of less than twelve months in the initial fiscal year, to determine the cited amount, they will divide the income obtained by the number of days comprising the period and multiply the result by 365 days. If the amount obtained is equal to or exceeds the referred amount, the facility referred to in this rule shall cease to apply from the beginning of the fiscal year and the provisions of the preceding paragraph shall apply.

Notice of application of the tax incentive

2.13.

For the purposes of Article 25 of the CFF and Rule 2.12 of this Resolution, taxpayers who apply the incentive referred to in Article 16, Section A, Fraction IV of the LIF, shall only present the notice referred to in the cited Article 25 when they apply said incentive for the first time, whether in the provisional payment return, definitive return, or annual return, as applicable. Said notice must be presented within fifteen days following the date of presentation of the return in which the incentive is applied, in accordance with procedure form 3/LIF "Notice presented by taxpayers manifesting the application of a tax incentive granted to those who acquire or import diesel or biodiesel and their mixtures for final consumption and which is for automotive use in vehicles destined exclusively for public and private transport of persons or cargo", contained in Annex 1-A of the RMF.

Title 3. Land Transport Sector for Intercity Passenger and Tourism Services

Verification of expenditures

3.1.

For the purposes of Articles 72, Fraction II, fourth paragraph, and 73 of the Income Tax Law (ISR), the persons referred to in the following fractions may consider deductible the expenditures made during the fiscal year, corresponding to the vehicle or vehicles they administer, provided they comply with the requirements established by tax provisions:

I.

Individuals and legal entities dedicated exclusively to land transport for intercity passenger and tourism services who have opted to pay the tax individually.

II.

Individuals dedicated exclusively to land transport for intercity passenger and tourism services who have opted to pay the tax through the coordinators of which they are members.

III.

Legal entities dedicated exclusively to land transport for intercity passenger and tourism services who fulfill their tax obligations through coordinators.

This facility applies even in cases where the tax receipt is issued in the name of the coordinator, according to the option chosen by the taxpayer to fulfill their tax obligations.

Withholding of ISR for operators, collectors, mechanics, and instructors

3.2.

Taxpayer individuals and legal entities, dedicated exclusively to land transport for intercity passenger and tourism services, who are subject to tax under the terms of Title II, Chapter VII or Title IV, Chapter II, Section I of the Income Tax Law (ISR), may opt to pay 7.5 percent for the concept of ISR withholdings, corresponding to payments effectively made to operators, collectors, mechanics, and instructors, instead of applying the corresponding provisions for the payment of salaries.

To calculate these withholdings, the base salary used for the calculation of contributions by said workers to the Mexican Social Security Institute (IMSS) shall be taken as reference, in accordance with applicable regulations; in which case, they must prepare and deliver, no later than February 15, 2026, an individualized list of said personnel, indicating the amounts paid to them in the period in question, in the terms in which it is prepared for the purposes of contributions made to the IMSS, as well as the withheld tax, in accordance with procedure form 94/ISR "Notice presented by taxpayers dedicated to the activity of land transport for intercity passenger and tourism services who exercise the option to pay 7.5 percent for the concept of ISR withholdings", contained in Annex 1-A of the RMF, in addition to issuing the CFDI and its complement for the corresponding payroll concept.

Regarding payments made to workers other than those indicated in this rule, the provisions of the Income Tax Law (ISR) shall apply.

This rule shall not be applicable when the taxpayers referred to in the first paragraph of the same provide their services predominantly to another legal entity resident in the country or abroad, which is considered a related party under the terms of the Income Tax Law (ISR).

Verification facilities

3.3.

For the purposes of the Income Tax Law (ISR), taxpayer individuals or legal entities, dedicated exclusively to land transport for intercity passenger and tourism services, who are subject to tax under the terms of Title II, Chapter VII or Title IV, Chapter II, Section I of the Income Tax Law (ISR), may deduct up to the equivalent of 8 percent of their own income from their activity, not exceeding $1,000,000.00 (one million pesos 00/100 M.N.) during the fiscal year, without the need to have documentation that meets tax requirements, provided that:

I.

The expense has been effectively incurred in the corresponding fiscal year and is directly linked to the taxpayer's activity.

II.

The expenditure for which the facility is applied is registered in the taxpayer's accounting by concept and in an accumulated manner during the fiscal year.

III.

The taxpayer pays the annual ISR on the deducted amount under the terms of this rule, applying a rate of 16 percent. The annual tax paid on said amount shall be considered definitive and shall not be creditable or deductible for tax purposes. In the case of coordinators or legal entities that pay tax on behalf of their members, they must make the payment of said tax on their behalf.

IV.

Taxpayers who opt for the facility referred to in this rule must make provisional payments for the annual tax referred to in the preceding fraction. These payments shall be determined considering the deduction made in the accumulated payment period of the fiscal year in question, applying a rate of 16 percent. Additionally, they may credit provisional payments made previously in the same fiscal year for the same concept. These provisional payments must be paid through the ISR returns for individuals, business and professional activity, or ISR for legal entities, coordinator regime, own tax or that of their members, no later than the 17th day of the month following that in which the deduction is made, or that corresponding in accordance with Article 5.1 of the "Decree that compiles various tax benefits and establishes measures for administrative simplification", published in the Official Gazette of the Federation (DOF) on December 26, 2013.

The deductible amount determined in accordance with this rule in the fiscal year in question shall be subtracted from the difference between the taxable income obtained in said year and the deductions authorized in accordance with the Income Tax Law (ISR) for which the facilities referred to in this Resolution do not apply, up to the amount of said difference.

In the case where the deductions authorized in accordance with the Income Tax Law (ISR) for which the facilities of this Resolution do not apply are greater than the taxable income obtained in the fiscal year, no amount shall be reduced for the concept of the deduction referred to in this rule.

The taxpayers mentioned in the first paragraph of this rule must report in the annual ISR return the amount corresponding to the deduction, indicating it in the field "Administrative facilities and deductible incentives" within the option "Deduction equivalent to up to 8% of own income without documentation meeting tax requirements for taxpayers dedicated exclusively to land transport for intercity passenger and tourism services".

The provisions of this rule shall not be applicable to expenses incurred by taxpayers for the acquisition of fuels to carry out their activity.

Concept of coordinator

3.4.

For the purposes of what is established in Articles 72 and 73 of the Income Tax Law (ISR), a coordinator shall be considered as any legal entity dedicated exclusively to land transport services for passenger and tourism, which groups and integrates with other similar and complementary individual and legal entities, constituted for the purpose of providing necessary services for the common activity of land transport for passenger and tourism. These elements integrate an economic unit with common interests and participate jointly and in unidentifiable proportions, with the following purposes:

I.

Coordinate and agree on the services provided jointly, including companies that provide services or own real estate dedicated to the activity of land transport for passenger and tourism. In the case of bus terminals or stations that are not members of any coordinator, they may be subject to tax under Title II, Chapter VII of the Income Tax Law (ISR), provided they are composed of companies dedicated to land transport for passenger and tourism and provide their services predominantly to companies of land transport for passenger and tourism. Furthermore, said centers or terminals shall not apply the facilities contained in Rules 3.2., 3.3. and 3.12. of this Resolution.

II.

Administer the funds authorized to them under the terms of the Resolution of Administrative Facilities in the Simplified Regime valid until December 31, 2001. Contributions made to said funds after said date are not considered deductible for ISR purposes.

III.

Fulfill tax obligations on behalf of each of their members globally.

IV.

Have a policy manual for the application of common expenses and their allocation to each of their members, which they must have available to tax authorities when requested.

Joint liability of coordinators

3.5.

Coordinators who opt to apply the facilities referred to in Rules 3.1., 3.2., 3.3. and 3.4. of this Resolution shall be jointly liable for their members when these have opted to pay tax individually, solely for the income, deductions, taxes, and withholdings that said coordinators have recorded in the settlement issued to the corresponding member, and must deliver to the tax authority annually the information of the income, deductions, taxes, and withholdings that they have recorded in the cited settlement corresponding to each of their members who has opted to pay tax individually.

Courier services

3.6.

For the purposes of Article 29 of the CFF, taxpayers, whether individuals, legal entities, or coordinators, dedicated exclusively to land transport for intercity passenger and tourism services, who are subject to tax under the terms of Title II, Chapter VII or Title IV, Chapter II, Section I of the Income Tax Law (ISR) and who provide courier services, may abstain from accompanying the goods in transport with the import declaration, the shipping or dispatch note, provided that the obligation to accompany the goods with the respective shipping guide is fulfilled and the CFDI is issued with the Carta Porte complement in cases where applicable in accordance with applicable legislation.

Shipping guides without chronological order

3.7.

Taxpayer individuals or legal entities, dedicated exclusively to land transport for intercity passenger and tourism services, who are subject to tax under the terms of Title II, Chapter VII or Title IV, Chapter II, Section I of the Income Tax Law (ISR), may use a consecutive numbering in the shipping guides issued by their shipping areas, simultaneously in all their branches, without having the obligation to follow a strict chronological order, provided that an ordered record by delivery date and number of shipping guides delivered to each branch is kept, which allows determining the income of each of these, as well as the numbering of the shipping guides pending to be used.

The taxpayers referred to in this rule may abstain from using different series for each branch in the shipping guides issued by their branches, as well as from recording the address of the establishment that issues the shipping guides, and must record in its place the fiscal address of the head office.

Fiscal address indicated on receipts or tickets

3.8.

For the purposes of what is established in Article 29-A, Fraction I of the CFF, taxpayer individuals or legal entities, dedicated exclusively to land transport for intercity passenger and tourism services, who are subject to tax under the terms of Title II, Chapter VII or Title IV, Chapter II, Section I of the Income Tax Law (ISR), may indicate as the fiscal address in the CFDIs or tickets they issue, that corresponding to the head office, instead of indicating the fiscal address of the location or establishment where said receipts are issued.

Sale of shares issued by companies dedicated to land transport for intercity passenger and tourism

3.9.

In the case of the sale of shares issued by legal entities dedicated exclusively to the activity of land transport for intercity passenger and tourism, who are subject to tax under the terms of Title II, Chapter VII of the Income Tax Law (ISR), that are sold by persons dedicated to the activity of land transport for intercity passenger and tourism, the acquirer is relieved of the obligation to make the 20 percent withholding established in Article 126, fourth paragraph of the Income Tax Law (ISR), provided that the seller accumulates to their own income from the activity of land transport for passenger and tourism, the profit determined by said sale under the terms of Articles 22, 23, 72, fourth paragraph, and 126 of the cited Law.

For the purposes of the preceding paragraph, the member of the coordinator who sells the shares or, if applicable, the coordinator through which this fulfills their tax obligations, must present a report on the sale of shares prepared by a registered public accountant, in accordance with what is established in Rule 2.10.1. of the RMF.

Acquisition of diesel, biodiesel, and their mixtures

3.10.

For the purposes of the tax incentive established in Article 16, Section A, Fraction IV of the LIF, it is considered that taxpayers dedicated to the activity of land transport for intercity passenger and tourism may apply the aforementioned tax incentive when they acquire diesel or biodiesel and their mixtures in the self-consumption service stations of said taxpayers, and in the tax receipt the information of the valid permit, issued in accordance with the Hydrocarbons Law to the fuel supplier, is recorded. Additionally, said permit must not be suspended at the time of issuance of the tax receipt.

Notice of option to pay tax through a coordinator

3.11.

For the purposes of Article 72, Fraction II, fourth paragraph of the Income Tax Law (ISR), those who opt to pay the ISR through one or more coordinators of land transport for intercity passenger and tourism, of which they are members, must present, in addition to the option notice, the notice of update of economic activities and obligations before the tax authorities and inform in writing the coordinator of which they are members, that they will exercise said option and that they have presented the update notice before the RFC. This procedure must be carried out within thirty days following the entry into force of this Resolution, in accordance with what is established in Article 30, Fraction V of the Regulations of the CFF and procedure form 71/CFF "Notice of update of economic activities and obligations", contained in Annex 1-A of the RMF.

In the case of taxpayers who in previous fiscal years have presented the option notice to pay tax through a coordinator and the notice of update of economic activities and obligations, referred to in this rule, it will not be necessary to present the corresponding notice again, unless they modify their activities, change the chosen option, or have the right to change it under the terms of the Income Tax Law (ISR) itself.

Acquisition of fuels

3.12.

Taxpayer individuals, legal entities, or coordinators, dedicated exclusively to land transport for intercity passenger and tourism services, who pay tax in accordance with Title II, Chapter VII or Title IV, Chapter II, Section I of the Income Tax Law (ISR), shall consider fulfilled the obligation established in Article 27, Fraction III, second paragraph of the Income Tax Law (ISR), when payments for fuel consumption are made with means other than named checks from the taxpayer's account; credit, debit, or service cards; or electronic wallets authorized by the SAT, provided that these do not exceed 15 percent of the total payments made for fuel consumption to carry out their activity. Additionally, in the tax receipt, the information of the valid permit, issued in accordance with the Hydrocarbons Law to the fuel supplier, must be recorded, and, if applicable, said permit must not be suspended at the time of issuance of the tax receipt.

Value Added Tax

3.13.

For the purposes of Article 72 of the Income Tax Law (ISR), coordinators who fulfill their obligations under the terms of Title II, Chapter VII of the cited Law, may fulfill their tax obligations regarding VAT on behalf of each of their members, applying what is established in the VAT Law.

Additionally, they must issue the settlement to their members through a CFDI of withholdings and payment information, with the following requirements:

I.

Name or corporate name, fiscal address, and RFC key of the legal entity, as well as the consecutive folio number.

II.

Place and date of issuance.

III.

Name of the member to whom it is issued, their RFC key or, if applicable, CURP, location of their business or address, and signature of the same or of the person receiving the document.

IV.

Global description of the concepts of income, deductions, and, if applicable, taxes and withholdings corresponding to the member in question.

Coordinators must issue the CFDI of withholdings and payment information, to which the "Settlement Complement" shall be incorporated, as published on the SAT Portal. In said CFDI, they must also record the information corresponding to the value of activities, the VAT transferred, the VAT transferred to them, as well as, if applicable, the paid amount on import.

For the purposes of this rule, those who opt to pay VAT through one or more coordinators of land transport for intercity passenger and tourism, of which they are members, must manifest to the RFC in their registration or notice of update of economic activities and obligations that they will carry out their activities "As members of a Coordinator that will pay its taxes" and will inform in writing to the coordinator of which

are members regarding the exercise of said option, indicating the folio and date of the procedure submitted to the tax authority.

For the purposes of the provisions in the preceding paragraph, taxpayers registered in the RFC on the date this rule enters into force will have thirty days following said date to submit their notice of update of economic activities and obligations, in accordance with Article 30, fraction V of the CFF Regulations and the procedure form 71/CFF "Notice of update of economic activities and obligations", contained in Annex 1-A of the RMF, as well as to inform the coordinator of which they are members about the exercise of said option.

Coordinators dedicated to foreign land passenger and tourism transport who fulfill tax obligations on behalf of their members will file the corresponding VAT declarations globally for their operations and those of their members, for the business activities carried out through the coordinator.

Information with VAT providers

3.14.

For the purposes of Article 32, fraction VIII of the VAT Law, coordinators of foreign land passenger and tourism transport who fulfill tax obligations on behalf of their members, will submit the information referred to in said fraction, globally for their operations and those of their members, in relation to the business activities carried out through the coordinator.

Credit of tax incentives

3.15.

Taxpayers, natural or legal persons, dedicated exclusively to foreign land passenger and tourism transport, who tax in accordance with Title II, Chapter VII or Title IV, Chapter II, Section I of the ISR Law, may effect the credit of the tax incentive corresponding to them in accordance with Article 16, section A, fraction IV, third paragraph of the LIF, against the own ISR caused in the exercise in which the fuel is imported or acquired; against the provisional payments referred to in rule 3.3., fraction IV; against the annual ISR referred to in fraction III of said rule 3.3. of this Resolution; or against the ISR withholdings made to third parties in the same exercise.

The taxpayers referred to in the preceding paragraph, who obtain in the fiscal exercise total annual income for ISR purposes less than 300 million pesos, in accordance with Article 16, section A, fraction V, second paragraph of the LIF, may effect the credit of the tax incentive referred to in said provision, against the own ISR caused in the same exercise in which the expenses for the use of toll road infrastructure are made; against the provisional payments referred to in rule 3.3., fraction IV; or against the annual ISR referred to in fraction III of said rule 3.3. of this Resolution.

The taxpayers referred to in this rule may opt to apply the credit of the mentioned incentives against the provisional ISR payments of the exercise, calculated in accordance with the provisions of the relevant Law, provided that the amounts of the mentioned tax incentives that they have credited in said provisional payments are not considered as part of the provisional payments they credit in the exercise declaration.

The credit of the mentioned incentives may be applied against the provisional payments on account of the annual ISR referred to in fraction III of rule 3.3. of this Resolution, calculated in accordance with the provisions of fraction IV of the same disposition, provided that the amounts of the mentioned tax incentives that they have credited against said provisional payments are not considered as part of the provisional payments they credit in the declaration of said annual ISR.

Taxpayers must consider as accumulative income for ISR purposes, the incentives referred to in this rule at the moment they effectively credit them.

For the purposes of the tax incentive established in Article 16, section A, fraction V, first paragraph of the LIF, when the total annual income obtained by the taxpayers referred to in the second paragraph of this rule reaches or exceeds 300 million pesos at any time during the exercise, they will cease to apply the credit of the tax incentive from the beginning of the exercise, for which they must file complementary declarations for previous months and, if applicable, pay the difference of the uncovered tax, updated for the period from the month in which the declaration in which the tax incentive was applied was filed, until the month in which the corresponding payment is made, in accordance with Article 17-A of the CFF; furthermore, the taxpayer must cover surcharges for the same period in accordance with Article 21 of the cited Code.

Taxpayers who begin activities may apply what is established in the third paragraph of this rule regarding the tax incentive referred to in Article 16, section A, fraction V, first paragraph of the LIF, when they estimate that their total income for the exercise will not exceed the amount established in said provision. When in the initial exercise they carry out operations for a period of less than twelve months, to determine the cited amount, they will divide the income obtained by the number of days comprising the period and multiply the result by 365 days. If the amount obtained is equal to or exceeds the referred amount, the facilitator referred to in this rule will cease to be applied from the beginning of the exercise and the provisions of the sixth paragraph of the same will apply.

Notice of application of the tax incentive

3.16.

For the purposes of Article 25 of the CFF and rule 3.15. of this Resolution, taxpayers who apply the incentive referred to in Article 16, section A, fraction IV of the LIF, will only have to submit the notice referred to in said Article 25, when they apply said incentive for the first time, either in the provisional or definitive payment declaration or in the annual declaration, as applicable. Said notice must be submitted within fifteen days following the date of submission of the declaration in which the incentive is applied, in accordance with procedure form 3/LIF "Notice submitted by taxpayers manifesting the application of a tax incentive granted to those who acquire or import diesel or biodiesel and their mixtures for final consumption and which is for automotive use in vehicles destined exclusively to public and private transport of people or cargo", contained in Annex 1-A of the RMF.

Title 4. Sector of Land Transport of Cargo of Materials and Land Transport of Urban and Suburban Passengers

Taxpayers who provide local services or public crane services

4.1.

Taxpayers dedicated exclusively to land transport of cargo who provide local services or public crane services, who tax in accordance with Title II, Chapter VII or Title IV, Chapter II, Section I of the ISR Law, may apply the facilitators established in this Title, unless they provide their services to members of the coordinator.

Verification facilitators

4.2.

For the purposes of the ISR Law, taxpayers, natural or legal persons, dedicated exclusively to land transport of cargo of materials or to land transport of urban and suburban passengers, who tax in accordance with Title II, Chapter VII or Title IV, Chapter II, Section I of the ISR Law, may deduct up to the equivalent of 8 percent of their own income from their activity, without exceeding $1,000,000.00 (one million pesos 00/100 M.N.) during the exercise, without the need to have documentation that meets fiscal requirements, provided that:

I.

The expense has been effectively made in the corresponding fiscal exercise and is directly linked to the taxpayer's activity.

II.

The expenditure for which the facilitator is applied is registered in the taxpayer's accounting by concept and in an accumulative manner during the fiscal exercise.

III.

The taxpayer makes the payment for the concept of annual ISR on the amount deducted in accordance with this rule, applying a rate of 16 percent. The annual tax paid on said amount will be considered definitive and will not be creditable or deductible for fiscal purposes. In the case of coordinators or legal persons who tax on behalf of their members, they must make the payment of said tax on behalf of the same.

IV.

Taxpayers who opt for the facilitator referred to in this rule must make provisional payments on account of the annual tax referred to in the previous fraction. These payments will be determined considering the deduction made in the accumulated payment period of the fiscal exercise in question, applying a rate of 16 percent. In addition, they may credit provisional payments made previously in the same fiscal exercise for the same concept. These provisional payments must be paid through the ISR natural persons, business and professional activity or ISR legal persons, coordinator regime, own tax or of their members, no later than the 17th day of the month following that for which the deduction is made, or that corresponding in accordance with Article 5.1. of the "Decree that compiles various fiscal benefits and establishes measures of administrative simplification", published in the DOF on December 26, 2013.

The deductible amount determined in accordance with the present rule in the exercise in question, must be subtracted from the difference between the accumulative income obtained in said exercise and the authorized deductions in accordance with the ISR Law for which the facilitators referred to in this Resolution are not applied and up to the amount of said difference.

In the case where the authorized deductions in accordance with the ISR Law for which the facilitators of this Resolution are not applied are greater than the accumulative income obtained in the exercise, no amount will be decreased by concept of the deduction referred to in this rule.

The taxpayers mentioned in the first paragraph of this rule must inform in the annual ISR declaration, the amount corresponding to the deduction, indicating it in the field "Administrative facilitators and deductible incentives" within the option "Deduction equivalent up to 8% of own income without documentation that meets fiscal requirements for taxpayers dedicated exclusively to land transport".

What is established in this rule will not be applicable to expenses incurred by taxpayers for the acquisition of fuels to carry out their activity.

Joint liability of coordinators

4.3.

Coordinators who opt to apply the facilitators referred to in rule 4.1. of this Resolution, will be jointly liable for their members when these have opted to tax individually, solely for the income, deductions, taxes and withholdings, that said coordinators have recorded in the settlement issued to the corresponding member, having to deliver to the tax authority annually the information of the income, deductions, taxes and withholdings, that they have recorded in said settlement corresponding to each of their members who have opted to tax individually.

Notice of option to tax through a coordinator

4.4.

For the purposes of Article 72, fraction II, fourth paragraph of the ISR Law, those who opt to pay the ISR through one or several coordinators of land transport of cargo of materials or of urban and suburban passengers, of which they are members, must submit, in addition to the option notice, the notice of update of economic activities and obligations to the tax authorities and inform in writing to the coordinator of which they are members, that they will exercise said option and that they have presented the update notice before the RFC. This procedure must be carried out within thirty days following the entry into force of this Resolution, in accordance with Article 30, fraction V of the CFF Regulations and the procedure form 71/CFF "Notice of update of economic activities and obligations", contained in Annex 1-A of the RMF.

In the case of taxpayers who in previous exercises have presented the option notice to tax through a coordinator and the notice of update of economic activities and obligations, referred to in this rule, it will not be necessary to present the corresponding notice again, unless they modify their activities, change the chosen option, or have the right to change it in accordance with the ISR Law itself.

Acquisition of fuels

4.5.

Taxpayers, natural or legal persons or coordinators, dedicated exclusively to land transport of cargo of materials or land transport of urban and suburban passengers, who tax in accordance with Title II, Chapter VII or Title IV, Chapter II, Section I of the ISR Law, will consider fulfilled the obligation established in Article 27, fraction III, second paragraph of the ISR Law, when payments for fuel consumption are made with means other than named checks from the taxpayer's account; credit, debit or service cards; or electronic wallets authorized by the SAT, provided that these do not exceed 15 percent of the total payments made for fuel consumption to carry out their activity. In addition, the fiscal receipt must contain the information of the valid permit, issued in accordance with the Hydrocarbons Law to the fuel provider and that, if applicable, said permit is not suspended at the time of issuance of the fiscal receipt.

Value Added Tax

4.6.

For the purposes of Article 72 of the ISR Law, coordinators of land transport of cargo of materials who fulfill their obligations in accordance with Title II, Chapter VII of said Law, may fulfill tax obligations in VAT matters on behalf of each of their members, applying what is established in the VAT Law.

In addition, they must issue the settlement to their members through a CFDI of withholdings and payment information, with the following requirements:

I.

Name or corporate name, fiscal address and RFC key of the legal person, as well as the consecutive folio number.

II.

Place and date of issuance.

III.

Name of the member to whom it is issued, their RFC key or, if applicable, the CURP, location of their business or address and signature of the same or of whoever receives the document.

IV.

Global description of the concepts of income, deductions and, if applicable, taxes and withholdings corresponding to the member in question.

Coordinators must issue the CFDI of withholdings and payment information to which the "Settlement Complement" must be incorporated, which will be published on the SAT Portal. In said CFDI, in addition, they must record the information corresponding to the value of activities, the VAT transferred, the VAT transferred to them, as well as, if applicable, the paid in importation.

For the purposes of this rule, those who opt to pay VAT through one or several coordinators, of land transport of cargo of materials, of which they are members, must manifest to the RFC in their registration or notice of update of economic activities and obligations that they will carry out their activities "As members of a coordinator that will pay their taxes" and will inform in writing to the coordinator of which they are members about the exercise of said option, indicating in the same, the folio and date of the procedure submitted to the tax authority.

For the purposes of what is established in the preceding paragraph, taxpayers registered in the RFC on the date this rule enters into force, will have thirty days following said date to submit their notice of update of economic activities and obligations, in accordance with Article 30, fraction V of the CFF Regulations and the procedure form 71/CFF "Notice of update of economic activities and obligations", contained in Annex 1-A of the RMF, as well as to inform the coordinator of which they are members about the exercise of said option.

Coordinators dedicated to land transport of cargo of materials who fulfill tax obligations on behalf of their members, will file the corresponding VAT declarations globally for their operations and those of their members, for the business activities carried out through the coordinator.

Information with VAT providers

4.7.

For the purposes of Article 32, fraction VIII of the VAT Law, coordinators of land transport of cargo of materials who fulfill tax obligations on behalf of their members, will submit the information referred to in said fraction, globally for their operations and those of their members, in relation to the business activities carried out through the coordinator.

Credit of tax incentives

4.8.

Taxpayers, natural or legal persons, dedicated exclusively to land transport of cargo of materials or to land transport of urban and suburban passengers, who tax in accordance with Title II, Chapter VII, or Title IV, Chapter II, Section I of the ISR Law, may effect the credit of the tax incentive corresponding to them in accordance with Article 16, section A, fraction IV, third paragraph of the LIF, against the own ISR caused in the exercise in which the fuel is imported or acquired; against the provisional payments referred to in rule 4.2., fraction IV; against the annual ISR referred to in fraction III of said rule 4.2. of this Resolution and against the ISR withholdings made to third parties in the same exercise.

The taxpayers mentioned in the preceding paragraph may opt to apply the credit of the mentioned incentive against the provisional ISR payments of the exercise, calculated in accordance with the provisions of the relevant Law, provided that the amount of the mentioned tax incentive that they have credited in said provisional payments is not considered as part of the provisional payments they credit in the exercise declaration.

The credit of the mentioned incentive may be applied against the provisional payments on account of the annual ISR referred to in fraction III of rule 4.2. of this Resolution, calculated in accordance with the provisions of fraction IV of the same disposition, provided that the amount of the mentioned tax incentive that they have credited against said provisional payments is not considered as part of the provisional payments they credit in the declaration of said annual ISR.

Taxpayers must consider as accumulative income for ISR purposes, the incentive referred to in this rule at the moment they effectively credit it.

Notice of application of the tax incentive

4.9.

For the purposes of Article 25 of the CFF and rule 4.8. of this Resolution, taxpayers who apply the incentive referred to in Article 16, section A, fraction IV of the LIF, will only have to submit the notice referred to in said Article 25, when they apply said incentive for the first time, either in the provisional or definitive payment declaration or in the annual declaration, as applicable. Said notice must be submitted within fifteen days following the date of submission of the declaration in which the incentive is applied, in accordance with procedure form 3/LIF "Notice submitted by taxpayers manifesting the application of a tax incentive granted to those who acquire or import diesel or biodiesel and their mixtures for final consumption and which is for automotive use in vehicles destined exclusively to public and private transport of people or cargo", contained in Annex 1-A of the RMF.

Transitory Provisions

First.

This Resolution will enter into force the day following its publication in the DOF and will be valid until December 31, 2025. However,

the facilitators contained in

this Resolution will be applicable for the entire fiscal exercise

Second.

For the purposes of rules 1.10., 2.10., 3.13. and 4.6., of this Resolution, taxpayers must issue settlements to their members or to the permit holders in question, through a CFDI of withholdings and payment information, from thirty days following that in which the "Settlement Complement" is published on the SAT Portal.

Until the aforementioned complement is published on the SAT Portal, taxpayers obliged to issue settlements in accordance with rules 1.10., 2.10., 3.13. and 4.6. of this Resolution, must issue them in accordance with the provisions established in the Resolution of Administrative Facilitators for the Sectors of Taxpayers Identified Therein for 2015, published in the DOF on December 30, 2014.

Respectfully,

Mexico City, February 6, 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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