New Tax Provisions: RFC Updates, Related-Party Transactions, CFDIs, Electronic Accounting, and Tax Incentives for Electronic Payment Methods

On October 30, 2026, the Fourth Resolution Amending the 2026 Miscellaneous Tax Resolution (Resolución Miscelánea Fiscal, RMF) was published in the Official Gazette of the Federation (Diario Oficial de la Federación, DOF), together with amendments to Annexes 1, 2, 7, 11, 14, 15, and 29.

The Resolution introduces several rules and modifies procedures related to tax compliance obligations, particularly regarding RFC updates, the issuance of CFDIs, crowdfunding transactions, penalty reductions, and tax incentives related to the use of electronic payment methods.

The following outlines the main changes and their implications for taxpayers:

1. SAT Non-Business Days (Rule 2.1.6)

November 2, 2026, is added as a non-business day for the Mexican Tax Administration Service (Servicio de Administración Tributaria, SAT), in addition to the previously established dates of April 2 and 3. This date must be taken into account when calculating tax deadlines expressed in business days, including the filing of submissions and responses to information requests.

2. Reduction of Late Payment Surcharges on Transfer Pricing Adjustments (Rule 2.1.52)

A procedure is established to request a reduction of late payment surcharges arising from adjustments to related-party transactions resulting from agreements reached with competent tax authorities. This provides an alternative for multinational groups seeking to resolve tax discrepancies arising from international disputes.

3. RFC Updates and Cancellation (Rules 2.2.5, 2.5.20, and 2.5.25)

The effects of RFC cancellation notices on digital seal certificates are clarified in cases involving mergers, spin-offs, and liquidations. The rules also address the suspension or cancellation of the RFC by the SAT, the procedures available to request clarification, and the verification of shareholders' and partners' information.

Recommendation: Keep corporate information up to date and periodically review the RFC status to prevent disruptions in invoicing.

4. New Deadlines for Electronic Accounting (Rule 2.8.1.6)

The deadlines for submitting the adjusted trial balance following the fiscal year-end (in the subsequent year) are amended:

The requirements for submitting and updating the chart of accounts are also clarified. Companies should review their closing and tax compliance calendars accordingly.

5. Reduction of Penalties for Improperly Reported Tax Losses (Rules 2.14.5 and 2.14.11)

A penalty reduction is available when taxpayers have reported tax losses exceeding those actually incurred. Subject to the applicable requirements, taxpayers may obtain a 90% reduction in the penalty, provided that they regularize their tax situation and pay the corresponding taxes and ancillary charges.

6. Other Relevant Provisions

Tax Regularization Through Advance Payments (Article Thirty of the Transitional Provisions). A mechanism is introduced for taxpayers with discrepancies or omissions identified through the tax authority's monitoring activities. Participation must be requested in accordance with Rule 2.1.49 and procedure form 54/CFF. This mechanism does not constitute automatic authorization to pay taxes in installments. It also does not restrict the SAT's authority to initiate or continue administrative enforcement proceedings.

Automotive Sector: Vehicle Identification Codes (Rules 8.5, 8.6, and 8.7). The rules governing the assignment and use of vehicle identification codes for purposes of the New Vehicle Tax (Impuesto sobre Automóviles Nuevos, ISAN) are updated. The applicable code must be included in the CFDIs issued for vehicle sales and provided at least 15 days before the sale to the consumer, as applicable. Manufacturers, assemblers, and distributors should review their invoicing and control processes.

Alcoholic Beverages (Rule 5.2.23). The grounds for removal from the relevant registry are expanded to include the expiration of certain marketing agreements and rulings involving the issuance of false tax receipts. In certain cases, removal may take place without granting the previously required ten-business-day period to remedy the irregularities. New specifications for certain electronic tax stamps (marbetes electrónicos) are also scheduled to take effect on December 31, 2026.

Other Industry-Specific Amendments. The Resolution includes CFDI-related administrative facilities for crowdfunding activities and authorized donee organizations; temporary updates to compliance obligations for digital platforms; and rules governing tax incentives linked to the “El Buen Fin” promotional lottery.

Final Considerations

These amendments combine operational adjustments with opportunities to reduce tax contingencies. We recommend identifying the rules applicable to each company and implementing the corresponding compliance adjustments in a timely manner.

At JA DEL RÍO, our specialized consulting teams are available to assist you with these and other relevant matters, helping ensure that your company meets the applicable requirements under this Resolution.

Should you have any questions, J.A. DEL RÍO's experts are available to provide guidance on compliance with tax provisions. Please feel free to contact us at contacto@jadelrio.com.