On November 7, 2025, the amendments to various tax provisions were published in the Official Gazette of the Federation, including the Federal Revenue Law (LIF), the Federal Tax Code (CFF) and the Law on the Special Tax on Production and Services (LIEPS), where relevant implications for the following sectors and topics are highlighted: financial services, insurance, digital services, verification powers, means of defense, and CFDIs, which are detailed below:
1) Federal Revenue Law (LIF)
Financial services (banking): The deduction of IPAB contributions is limited to only 25%.
Regarding bad bank loans, special treatment is eliminated; therefore, its deductibility will be when a notorious impossibility of collection expires or is demonstrated.
Insurers (VAT on claims in kind)
Value added tax (VAT) is considered non-creditable when the compensation is paid in kind.
2) Federal Tax Code (CFF)
Powers of verification (new "express" visit)
The possibility of expeditious home visits is incorporated when it is presumed the use of false CFDIs. This may generate immediate suspension of digital stamps. In these cases, the deadlines for a mean of defense will be five days; the resolution will be issued 15 business days later (24 max.).
CFDIs and materiality
The fact that the CFDIs must cover existing, true or real legal acts is incorporated; otherwise, they are considered false for tax purposes, additionally the tax authority may disregard the effects of a CFDI in any audit without exhausting the provisions of the previous section.
Means of defense
The catalogue of means of collateral is maintained and reordered, with an order of priority based on liquidity. The deposit note through the Banco del Bienestar or authorized institution is expressly incorporated. In this regard, the possibility of guaranteeing with credit securities or credit portfolios is eliminated. Likewise, the "exemption from guarantee" in the appeal for revocation is eliminated. It is only maintained in IMSS and INFONAVIT resources.
Offences and offences (key selection)
The issuance of CFDIs is conditioned to the consideration of the proof of tax situation; when appropriate there will be infractions, fines and possible closure for recidivism.
In the event of a successful closure seal, a new infraction is established with a fine and double closure.
It is considered a crime to issue, buy, sell or use false CFDIs; This will also be applied to platforms that advertise their purchase and sale with malice.
A penalty of three to six years is established for incorporating data or false documents.
Digital services (compliance/technology)
Access and enforceability of information to platforms are reinforced, and there will be liability when they facilitate the purchase and sale of false CFDIs, as well as the tax authorities are empowered so that as of April 1, 2026, they can have permanent online and real-time access to the information in their systems or records.
3) LIEPS
Increases in IEPS quotas are incorporated into the tobacco, cigars and nicotine-containing products, as well as drinks with added sugar or sweeteners.
In addition, a new tax is created on games with online bets and draws offered from abroad. The reform includes digital betting, sweepstakes and contest services provided by residents abroad without an establishment in Mexico. These digital foreign betting services were set a rate of 50% of IEPS.
Finally, an IEPS of 8% is incorporated on certain video games due to their violent content.
As always, the team of the Tax and Legal Practice at KPMG Mexico is at your service to analyze in detail the effects that the application of the above provisions may have on your company.
