On December 30, 2024, the Periodic Amendments to the Tax Law, [in Spanish: Resolución Miscelánea Fiscal], (RMF), for 2025 and its Annexes were published in the Official Gazette of the Federation [in Spanish: DOF]. It is important to note that the Periodic Amendments to the Tax Law compiles provisions on tax matters, including respective regulations and updates with regard to the previous year. Therefore, it serves as an indispensable guide for taxpayers.

Below is a summary of the most relevant changes and updates:

Federal Tax Code 

Procedure that must be observed for obtaining tax compliance opinion

Rule 2.1.36, which pertains to the procedure for obtaining the tax compliance opinion, has been updated to specify that taxpayers registered in the Federal Registry of Taxpayers, [in Spanish: RFC], under "No tax obligations" are considered compliant with their tax obligations related to Income Tax withholdings for professional services, leasing, and VAT withholdings.

Taxpayer consent to share fiscal information with Nacional Financiera, so that  Nacional Financiera request information about the same of credit risk companies

The rule requiring the consent of small and medium-sized companies for the Tax Administration Service, [in Spanish: SAT], to share fiscal information with Nacional Financiera to generate a credit rating has been eliminated for 2025.

Registration in the Federal Registry of Taxpayers, [RFC], for Mexicans living abroad

An addition allows Mexican individuals living abroad, who only earn income from wages or other subordinate personal services, to register in the Federal Registry of Taxpayers without tax obligations. This also applies to individuals without tax obligations in Mexico, as per procedure 321/CFF "Request for registration in the Federal Registry of Taxpayers for individuals through the virtual office."

Modification or incorporation of information of partners or shareholders, and legal representatives

To enable the system to automatically calculate ownership interest, the required notice must include the number of shares, capital stock, contribution certificates, or any other term used to denote shares in the capital stock of their partners or shareholders.

Digital Tax Receipts [in Spanish: CFDI]

Issuance of Digital Tax Receipts for payroll for the 2024 fiscal year 

Payroll CFDIs issued with errors or omissions between January 1 and December 31, 2025, may be corrected until February 28, 2025. These Digital Tax Receipts must reflect the payment date corresponding to 2024.

Income Tax [in Spanish: ISR] 

Legal entities authorized to receive donations

Section 3.10.1 has been added. The regulations included in this section mainly establish the method, means, and requirements for authorization and compliance regarding declarations, necessary documentation to verify the allocation of resources for authorized activities, as well as the possibility of receiving foreign donations for specific activities, and the cancellation process.

Taxpayers who can contribute to the Simplified Trust Regime [in Spanish: RESICO] for individuals 

Those taxpayers who can contribute to the Simplified Trust Regime are partners and shareholders in credit unions exclusively engaged in agricultural, livestock, forestry, or fishing activities, provided they do not receive income from the aforementioned legal entities.

Exemption from filing monthly and annual returns for individuals enaged solely in agricultural, livestock, forestry, or fishing activities with exempt income must issue a Digital Tax Receipt for the activities they carry out in order to opt out of filing the corresponding monthly and annual returns.

Tax payment on income from agricultural, livestock, forestry, or fishing activities

Individuals whose income in the fiscal year exceeds more than $900,000.00 MXN (nine hundred thousand pesos 00/100 Local Currency) must pay Income Tax from the month that this occurs, and only on the earned income that exceeds the said limit.

Taxpayers who stop contributing to the Simplified Trust Regime (RESICO) of legal entities 

The time in which legal entities cease to qualify for the Simplified Trust Regime has been modified. It will now be from the fiscal year immediately following that in which their income exceeds $35,000,000.00 MXN (thirty-five million pesos 00/100 Local Currency).

Reimbursement of Income Tax Refund Claim from the Simplified Trust Regime (RESICO) for individuals 

Taxpayers who contribute according to this regime may request a refund of credit balances declared in their definitive monthly return in the following month, or opt for requesting a refund jointly, provided that the said request be for the total amount of the credit balances for the fiscal year, and that they request it as of January 17 of the immediate subsequent fiscal year to which the aforementioned balances correspond, and as such, they must use the Electronic Refund Request Form, [in Spanish: FED], that is available on the website of the Tax Administration Service [in Spanish: SAT], accompanied by documentation that is indicated as information sheet 9/CFF “Request for Credit Balance Refund and Payments for Improper Federal Tax Auditing or Foreign Trade Auditing”.  

Requirement to enable the tax mailbox for RESICO individual taxpayers

The obligation to enable the tax mailbox for individual RESICO taxpayers has been deferred until January 1, 2026.

Elimination of the notice to opt for the RESICO regime 

The Periodic Amendments to the Tax Law for 2025 no longer includes the rule regarding the update notice for economic activities and obligations for taxpayers opting for the RESICO regime.

Value Added Tax (VAT)

Refund of VAT balances from investment projects for fixed assets

Regulation 4.1.6 has been amended for establishing that refund requests must be submitted via the Electronic Refund Request Form, (FED), system, in accordance with regulation 2.3.4 and information sheet 10/CFF "Request for refund of VAT balances for the agricultural sector and projects involving fixed asset investment that produce and distribute products allocated for food, patent medicine, and in the preoperative period", as contained in Attachment 1-A. 

VAT refund requests for diplomatic missions and international organizations

Diplomatic missions and international organizations must submit VAT refund requests monthly through their embassy or office to the AGGC official office, using the official form and annex as specified on the SAT portal and the Ministry of Foreign Affairs' Protocol Directorate portal.

Required documentation for VAT refunds for foreign tourists Foreign tourists leaving Mexico by air or sea must present a printed receipt for goods purchased at stores to obtain VAT refunds.

Concession license for VAT refunds to foreigners

The cash payment limit for VAT refunds to foreigners has been reduced to $2,000.00 MXN. Electronic payment refunds must be completed within 40 calendar days of receiving the request.

Special Tax on Production and Services (IEPS)

Control of labels or seals in the importation of alcoholic beverages

It is included among the reasons for deregistration from the registry:

• When the legal representatives and authorized legal representatives to collect labels or seals are not up to date in the fulfillment of their tax obligations in their opinion of compliance with tax obligations.
• Failure to give notice in the event of a change of tax domicile, establishment or opening of establishment and in general any place used for the performance of activities.
• When it is detected that the tax domicile and/or establishments where alcoholic beverages are manufactured, produced, packaged or stored, modifying the text, is different from that registered in the Registry of Alcoholic Beverage Taxpayers.
• Failure to provide the tax authority through the SAT website with the information requested through the Electronic Label and Seal Format (FEMYP), regarding the use of all physical labels, seals or electronic labels, which have lost their validity in terms of rule 5.2.25.
• Not being registered and active in the registry of importers, in the case of importing alcoholic beverages. The text is modified by adding the word “Registered” and at least one of the economic activities established in the section What conditions must I comply with? of subsections m) to x) of the processing form 23/IEPS "Application for registration in the Registry of Taxpayers of Alcoholic Beverages in the RFC" is carried out, contained in Annex 1-A.

Likewise, it is added that when the tax authority detects that the taxpayer is in any of the causes for deregistration, the direct deregistration of the registry will be carried out, which will be notified through the tax mailbox and, if the taxpayer so requires, he/she may submit his/her application for registration, in terms of form 23/IEPS "Application for registration in the Registry of Alcoholic Beverage Taxpayers in the RFC" contained in Annex 1-A.

Report on the use of physical or electronic labels, both printed and adhered, and seals

The numeral and the name of said rule are modified by adding the word “Seals”, also for the purposes of the FEMYP.

It is added that the physical or electronic labels may not be used and reported outside the validity periods established in the processing forms 2/IEPS "Advance request for labels or seals for the importation of alcoholic beverages", 4/IEPS "Request for the provision of physical labels and seals for national alcoholic beverages", 6/IEPS "Request for the provision of physical labels and seals for imported alcoholic beverages", 7/IEPS. 

Document proving that one is an IEPS taxpayer

The text is modified considering that the “Tax Status Certificate” proves that the taxpayer is an IEPS taxpayer when the obligations of said tax are indicated in said attached document, thus, eliminating the concept of “Tax Identification Card”.

Elimination of the report on labels or seals through MULTI-EPS

Rule 5.2.24 Report on labels or seals through the program “Multiple Informative Return of the Special Tax on Production and Services” is eliminated.

Other Provisions

Promotion of investment in the industrial wellbeing poles Progreso I and Mérida I of the state of Yucatán

A special chapter is considered regarding various regulations for those taxpayers who are in the assumptions of the Decree published in the DOF on June 28, 2024.

Tax stimulus contained in the Federal Revenue Act for 2025 (PF and PM whose total income in the tax year in question, for the purposes of the Income Tax Act (LISR), has not exceeded 35 million pesos)

Rules related to establishing which taxpayers are “not” eligible for said incentive and the procedure regarding the forgiveness of fines, surcharges and execution costs corresponding to the tax year 2023 or prior for up to 100% are considered, also establishing that said incentive is not applicable to legal entities that are not ISR taxpayers.

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.