An opportunity to obtain a reduction of up to 100% of fines, surcharges, and collection costs

The Federal Revenue Law for Fiscal Year 2026 (Ley de Ingresos de la Federación, “LIF 2026”) provides for a tax incentive available to certain taxpayers, under which they may obtain a reduction of up to 100% of the fines, surcharges, and collection costs related to certain tax debts.

The incentive is primarily aimed at debts corresponding to fiscal year 2024 and prior fiscal years; therefore, it is not a general reduction applicable to fines or debts arising from fiscal year 2025 onward. Application of the benefit is subject to compliance with the requirements and conditions set forth in the LIF 2026.

The incentive has been in effect since January 1, 2026, and represents an opportunity for eligible taxpayers to regularize their tax status during fiscal year 2026.

Who is eligible?

The benefit is available to individuals and legal entities whose total income for fiscal year 2024 did not exceed MXN $300 million, and who have certain final or uncontested tax liabilities (créditos fiscales firmes o consentidos) whose administration and collection fall under the authority of the Tax Administration Service (SAT) or the National Customs Agency of Mexico (ANAM).

Items that may qualify for the incentive include:

• Federal taxes owed directly, withheld, or passed on to third parties.
• Non-tax federal revenues (aprovechamientos).
• Countervailing duties (cuotas compensatorias).
• Fines arising from non-compliance with tax obligations.
• Fines with aggravating circumstances.
• Surcharges.
• Collection costs.

The benefit consists of a 100% reduction of fines, surcharges, and collection costs, provided that the requirements set forth in the LIF 2026 are met.

In which cases does it apply?

The incentive mainly covers the following scenarios:

1. Debts corresponding to 2024 or prior fiscal years

Taxpayers with debts corresponding to fiscal year 2024 or prior years may apply the incentive, provided that they:

• File the corresponding tax returns, where applicable.
• Pay the debt in a single lump-sum payment.
• Make the payment no later than December 31, 2026.

2. Taxpayers subject to tax audits

Taxpayers subject to the tax authority’s audit powers (facultades de comprobación) may also access the incentive, provided that they:

• Correct the irregularities identified.
• Self-correct their tax position within the applicable period.
• Complete the self-correction, in any case, no later than December 31, 2026.

Application of the incentive must be reported to the tax authority conducting the audit and may be carried out during the audit procedure and before the corresponding resolution is served.

3. Final tax liabilities

In the case of final tax liabilities assessed by the federal tax authority, the taxpayer must, among other requirements:

• Not have challenged the tax liability or, if applicable, withdraw the legal challenge filed.
• Withdraw any administrative review appeal it may have filed.
• File the corresponding request with the SAT no later than October 31, 2026.

Once the request has been filed, the SAT may issue the corresponding payment form within the following 15 calendar days.

Key dates

In addition, the 2026 Miscellaneous Tax Resolution (RMF 2026) sets out specific rules for applying the incentive and certain payment facilities; therefore, the procedure should be analyzed based on the particular circumstances of each tax liability.

Who is not eligible for the benefit?

The incentive does not apply, among other cases, to taxpayers who:

• Have received certain benefits of forgiveness, reduction, or decrease of tax liabilities under the general and mass forgiveness programs referred to in the LIF 2026.
• Have received the tax incentive provided for in the Federal Revenue Law for Fiscal Year 2025 (LIF 2025).
• Fall under any of the other exclusion scenarios expressly established in the LIF 2026.
• Accordingly, having a tax debt does not automatically grant access to the benefit; it is necessary to verify the nature of the tax liability, the fiscal year to which it corresponds, and the taxpayer’s tax status.

We recommend conducting this analysis in advance, particularly in cases where a request must be filed with the tax authority before October 31, 2026.

J.A. DEL RÍO offers a wide array of specialized consulting services to assist you with these and other matters, in order to ensure that your project complies with the applicable characteristics  contained in this agreement.

If you have any questions, J.A. DEL RÍO can provide you with our experts to advise in matters concerning compliance with your legal and tax obligations. Once again, please let us know if we may be of any further assistance to you at: contacto@jadelrio.com.