On November 7, 2025, the Federal Revenue Law (Ley de Ingresos de la Federación) for fiscal year 2026 was published in the Diario Oficial de la Federación. Among other provisions, this law includes tax incentives for taxpayers with outstanding liabilities, final tax assessments, or those currently subject to tax audit procedures corresponding to fiscal year 2024 or prior years, who choose to self-correct. The incentive consists of a 100% condonation of penalties, interest, enforcement expenses, and countervailing duties.
Eligible Taxpayers
This benefit is available to taxpayers who meet the following requirements:
a. Did not exceed MXN $300 million in taxable income during 2024.
b. Have final, consented, or assessed tax liabilities determined by the SAT or ANAM arising from fiscal year 2024 or earlier.
c. Have outstanding tax debts or are under audit procedures and choose to self-correct to qualify for the incentive.
d. The tax liabilities must relate to federal taxes (own, withheld, or passed-through), government fees, penalties, or countervailing duties.
Excluded Taxpayers
This incentive is not available to the following:
I. Taxpayers who previously benefited from broad or mass tax-debt forgiveness programs.
II. Taxpayers with a final criminal conviction for tax-related offenses.
III. Taxpayers listed under Articles 69-B and 69-B Bis of the Código Fiscal de la Federación.
IV. Taxpayers under the jurisdiction of the Large Taxpayers Office (Administración General de Grandes Contribuyentes).
Key Benefits of the Incentive
Additional advantages include:
- Suspension of the Administrative Enforcement Procedure without requiring a tax guarantee.
- The incentive is not considered taxable income for income tax purposes.
Scope of the Condonation
The incentive allows for the condonation of penalties, surcharges, enforcement expenses, and countervailing duties related to:
- Final or consented tax liabilities administered and collected by the SAT or ANAM, including those arising from foreign trade operations.
- Liabilities for omitted federal taxes.
- Liabilities for omitted withheld or passed-through taxes.
- Liabilities for omitted government fees (aprovechamientos).
- Penalties for non-compliance with tax obligations, including obligations other than payment.
- Aggravated penalties and countervailing duties.
It is important to note that the incentive does not condone the principal amount of the tax liabilities—only the related ancillary charges.
Requirements and Procedures to Apply the Incentive
- Taxpayers with Outstanding Debts
- Must file the corresponding tax returns and make a single lump-sum payment no later than December 31, 2026.
- Taxpayers Under Audit Procedures
- Must correct all identified irregularities and self-correct in accordance with the applicable procedure, no later than December 31, 2026.
- Must notify the tax authority conducting the audit of their intention to apply the incentive, either during the audit procedure or prior to issuance of the resolution.
- Taxpayers with Final Tax Assessments
- Must submit their application no later than October 31, 2026.
- The tax authority will issue the payment form within 15 calendar days following the application; the taxpayer will have 15 calendar days to make the payment.
- Taxpayers who have challenged the assessment must withdraw the legal remedy previously filed.
In summary, this new incentive applies to taxpayers whose taxable income did not exceed MXN $300 million in 2024, thereby expanding the pool of eligible taxpayers compared to the incentive contained in the 2025 Federal Revenue Law.
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.
