January 2026

The 28 from December to 2025 was published in the Official Gazette of the Federation the Miscellaneous Tax Resolution (RMF) for exercise 2026, That is why we consider it essential to point out the following modifications that could be useful:

Title 2.- Fiscal Code of the Federation

• Ruler 2.1.20. Monthly Surcharge Rate – The monthly rate of late fees applicable in the fiscal year 2026, fixing it on 2.07%. Compared to FMR 2025, in which the rate was 1.47%, is observed a relevant increase in the financial cost of non-compliance, with direct impact on tax credits and late payments.

• Ruler 2.1.36. Compliance Opinion – The rule reinforces the validation criteria reviewed by the authority, expressly incorporating additional control assumptions, such as verification related to issuers of irregular tax receipts (49 Until the CFF), compliance with obligations regarding the controlling beneficiary and the consolidation of the treatment applicable to tax credits paid on account.

• Ruler 2.4.17.  -A formal procedure is incorporated so that, in case of refusal of registration to the RFC of a legal entity derived from tax inconsistencies, including those related to partners, shareholders or legal representatives, said situation may be distorted within a period of 10 days.

• Ruler 2.7.1.35. – Limits the tacit acceptance of the cancellation of low-amount CFDI only to vouchers with complementary payments, reducing the cases in which the sender can cancel without intervention from the receiver.

• Ruler 2.7.5.6. – The rule allows taxpayers to correct for the only occasion the CFDIs of payroll issued in the exercise 2025 containing errors or omissions, provided that the new receipt is issued no later than 28 February 2026, The substituted vouchers are canceled and the corrected CFDI is recorded as payment date the day of 2025 in which the payment was made to be considered issued in that fiscal year; The facility does not exempt from the payment of differences or from the updating and surcharges that may apply..

• Ruler 2.9.9. Fact or Omissions – It is modified with respect to legal entities that wish to exercise the right to have the tax authority inform them of the facts or omissions detected during a review, they must accompany the necessary documentation that proves the information provided. (constitutive writing, testimony or policy issued by a notary public). If not, It will be understood that they do not exercise said right.

• Ruler 2.9.21. Online access Tax Information Digital Platforms – The obligation of taxpayers who operate digital platforms to grant the SAT online access to detailed information on their operations is established.. This information must be available permanently, be updated no later than the day after the corresponding day and kept for five years, including operations data, impuestos, users and service providers, in accordance with article 30-B of the CFF.

• Ruler 2.11.1. Installment Payment Request – Contributions and benefits derived from import or export operations can access partial or deferred payment schemes., option that was previously restricted.

• Ruler 2.12.4. Fiscal Interest Guarantee – Redefines the procedure to offer guarantees of fiscal interest when these are not granted in the order provided for in the article 141 Del CFF, requiring the taxpayer to document the impossibility of guaranteeing in accordance with the preferential modalities and present a statement under oath of truth., strengthening the control of authority in these cases.

Title 3.- Impuesto sobre la renta

• Ruler 3.2.4. Income accumulation option for total or partial collection of the price – La RMF 2026 maintains in force the facility for taxpayers of Title II of the Income Tax Law (legal persons) that receive total or partial collections before delivering the good or providing the service do not accumulate said amounts for the purposes of provisional payments in the month of their collection., being able to recognize them as cumulative income until the end of the year. This scheme allows, además, deduct the associated estimated cost of goods sold, aligning the tax recognition of income and costs with the operational reality of the business.

• Ruler 3.10.1.6. Accreditation of activities receiving deductible donations –Reinforce requirements to accredit the activities for which authorization to receive deductible donations is obtained or maintained, requiring the description of specific activities and their material accreditation, without the simple transcription of the corporate purpose being sufficient. For educational grantees and scholarship granting organizations, additional requirements are reinforced.

Title 9.- Federation Income Law

• Rules 9.3.1 a 9.3.5. Return or Enter Foreign Resources into the country La RMF 2026 establishes the operational rules of the program for the return or entry of resources held abroad to the country, in accordance with the stimulus provided in the Federal Income Law, needing requirements, deadlines and conditions for its application.

• Rules 9.4.1 a 9.4.6. FIFA World Cup 2026 -Tax regime applicable to the FIFA World Cup 2026. La RMF 2026 establishes a special tax regime applicable exclusively to FIFA, its subsidiaries, affiliates, suppliers and service providers directly linked to the organization and execution of the FIFA World Cup 2026, specifying operational rules regarding tax compliance, applicable taxes and formal obligations. These provisions have a temporary scope, Therefore, they are only relevant for taxpayers who directly participate in said event..

Title 12.- Provision of Digital Services

• Ruler 12.2.12. Informative Statement games with bets and raffles – A specific obligation is incorporated for intermediation platforms in games with bets and raffles: report to SAT, withdrawal and indemnities or other payments 10 of the following month, the information on the services for which the consideration has been charged and the corresponding IEPS.

Transients

• Third – It is established that tax authorities other than the SAT (INFONAVIT, PROFESSION, CONAGUA and state tax authorities) They will be able to use the tax mailbox for electronic notifications from 31 from December to 2026. Until then, notifications must be made in accordance with the article 134 Del CFF.

• Room – It is deferred until January 1, 2027 the application of the provisions of article 86-D of the Federal Tax Code for taxpayers who have not enabled the tax mailbox or do not have their contact methods updated.

DFK Mexico – Fiscal Committee