On October 1, 2026, the Mexican Tax Administration Service (Servicio de Administración Tributaria or SAT) published the Second Resolution Amending the 2026 Miscellaneous Tax Resolution (Resolución Miscelánea Fiscal, RMF) and Annex 2 in the Official Gazette of the Federation (Diario Oficial de la Federación). The publication amends Rules 9.4.4. and 11.7.3., adds Transitory Article Twenty-Ninth, and publishes the Second Amendment to Annex 2.
The Resolution addresses three topics: income tax (Impuesto sobre la Renta, ISR) applicable to players residing abroad during the 2026 FIFA World Cup; calculation of the base price of diesel fuel; and the validity through 2027 of certain authorizations to receive tax-deductible donations. It entered into force on October 1, 2026.
What changed on October 1, 2026?
Rule 9.4.4. establishes that players or their representatives must remit ISR no later than the day following receipt of the income. They may also elect to make the payment through FIFA Member Associations other than the Host Association, in accordance with Form 117/CFF set forth in Annex 2.
Rule 11.7.3. incorporates adjustments to the calculation of the base price of diesel fuel, including an amount of MXN 1.06 per liter to be deducted for October 1. In addition, Transitory Article Twenty-Ninth establishes conditions under which certain authorized donee organizations may maintain the validity of their authorizations throughout 2027.
Key Considerations
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Topic
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Business implications
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Players’ income tax
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Payment is due no later than the day following receipt of the income. Alternatively, payment may be made through FIFA Member Associations.
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Form 117/CFF
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Establishes the procedure for reporting or processing ISR payments applicable to players residing abroad.
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Base price of diesel fuel
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An amount of MXN 1.06 per liter is to be deducted for October 1.
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Authorized donee organizations in 2027
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Conditions for maintaining the validity of certain authorizations throughout 2027.
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Legal basis: Rules 9.4.4. and 11.7.3.; Transitory Article Twenty-Ninth; and the Second Amendment to Annex 2 of the 2026 RMF.
Immediate Implications for Businesses
The publication primarily concerns tax matters and does not directly amend customs entry requirements, customs clearance procedures, certification requirements, or foreign trade promotion programs. For companies engaged in foreign trade, it is advisable to assess the implications of these provisions when operations involve the 2026 FIFA World Cup, fuel logistics, or circumstances applicable to authorized donee organizations.
Depending on their business activities, companies should consider the following:
- FIFA World Cup 2026: Verify the ISR payment and reporting procedures established under Rule 9.4.4. and Form 117/CFF.
- Logistics and fuel: Determine whether tax models, budgets, or contracts incorporate the diesel base price established under Rule 11.7.3.
- Authorized donee organizations: Where applicable, confirm compliance with the conditions set forth in Transitory Article Twenty-Ninth to maintain the authorization throughout 2027.
Conclusions
The Second Resolution updates specific tax procedures, effective October 1, 2026. No direct changes to customs operations have been identified for foreign trade purposes. Accordingly, the analysis should focus on the tax and operational circumstances applicable to each business.
Source: Official Gazette of the Federation, October 1, 2026
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