16/2025

November 2025

Relevant tax reforms 2026

TAX CODE OF THE FEDERATION

Last 07 On November of the current year, the Decree through which various modifications were made to the Federal Tax Code was published in the Official Gazette of the Federation., modifications that, New Obligation in relation to the Controlling Beneficiary 01 of January of 2026, may be applicable to the Tax Authority and must be taken seriously by each and every one of us., because they could have important consequences in relation to your daily operations.

Through this flash we will mention some of them, which consist of:

Temporary Suspension of the Digital Seal Certificate (CSD).

The Tax Authority may temporarily restrict the Digital Seal Certificate (CSD) if you detect that the declared income, the withheld tax or the information do not match the income or value of activities indicated in the digital tax receipts online (CFDI), payment supplements or bank statements, files or documents that you have in your possession or access. (Art. 17-H bis section VII, CFF).

During this year, the Tax Authority through electronic communications, invitation letters and deep surveillance, There is information on differences between what was declared and the CFDI issued or received, differences that have been clarified before the authority itself, duly founded and motivated, Nevertheless, New Obligation in relation to the Controlling Beneficiary 01 January of next year, The Tax Authority will have the powers to temporarily restrict the CSD, so there will be a legally based procedure (Art. 17-H To) in order to clarify these differences or, If applicable, “self-correct” so that the Tax Authority is satisfied and operations can continue..

New verification power.

The Tax Authority, as we well know, has various verification powers., the same ones we know as audits, now, with the new reforms to the Federal Tax Code, A new verification power was implemented (Art. 42, fraction V, subsection g and 49- Until the CFF), which would be initiated in order to verify that the CFDI issued cover existing operations, true or real legal acts, when the authority presumes otherwise.

The taxpayer must verify that the CFDI are real through a procedure established in article 49-Bis of the CFF, that the authority itself will initiate, the most relevant points of this procedure:

1. Procedure notified, the suspension of the issuance of said vouchers will be ordered.
2. The taxpayer will have a period of 5 days to prove, through its materiality that the CFDI are real and distort the presumption of the Tax Authority (without right of extension)
3. The Authority will have a period of 15 days to issue a resolution.
4. If the Authority considers that the CFDI are false, The name and RFC will be published on the SAT and DOF portal.
5. Taxpayers who received CFDIs declared as false must self-correct fiscally, through a supplementary statement during the 30 following business days once published on the SAT or DOF portal.
6. If for some reason it is not corrected by submitting your complementary declaration, the Tax Authority will restrict the digital CSD.

The procedure that was implemented has the purpose of regulating, through a formal process, possible cases of false CFDI that cover simulated operations and, in turn, provide taxpayers with the possibility of exhibiting documentation with which they can prove or refute the presumptive declaration.

Therefore it is suggested that, starting next year, Each and every one of us meticulously review the SAT and/or DOF portal and avoid falling into the situation of a third party that could cause the restriction of your CSD..

DFK MEXICO