On May 4, 2026, the Ministry of Finance and Public Credit (SHCP, for its acronym in Spanish) published, in the evening edition of the Federal Official Gazette (DOF, for its acronym in Spanish) the agreement issuing general criteria and operational guidelines of an orientative nature for the promotion of productive investment and tax compliance. The agreement establishes general criteria applicable within the scope of authority of the Mexican Tax Administration Service (SAT, for its acronym in Spanish), in coordination with such authority, with the purpose of strengthening legal certainty, administrative efficiency and the promotion of productive investment.
The agreement further states that the criteria are intended to serve as orientative and programmatic in nature and are issued without prejudice to the powers granted to the tax authorities under applicable law. Accordingly, the agreement clarifies that such criteria do not constitute a limitation, waiver, or modification of the legal powers of tax authorities.
Among its main provisions, the agreement establishes that tax authorities shall observe and promote compliance with international treaties and applicable provisions intended to prevent double taxation for the benefit of taxpayers. It also provides that tax audit powers should, whenever possible, be exercised in a concentrated manner, seeking, as a general rule, to conduct a single comprehensive review per fiscal year and taxpayer through the analysis of representative samples of information, while avoiding simultaneous reviews of different fiscal years, except where legal provisions or particular circumstances require the exercise of additional powers.
The agreement also provides that audits and other tax enforcement actions must be carried out in accordance with the deadlines, procedures, and requirements established under tax legislation, with the purpose of providing legal certainty and promoting consistency in audit criteria. In addition, it states that audits shall observe the principle of non-retroactivity in the application of review criteria, as well as the applicable statute of limitation periods for the exercise of tax audit powers.
Regarding restrictive measures, the agreement establishes that tax authorities shall seek to use temporary restrictions on digital seal certificates and, where applicable, the cancellation of registrations, only as mechanisms of last resort, prioritizing preventive or corrective actions and guaranteeing the right to be heard in accordance with applicable legal provisions, without prejudice to their immediate application when required under tax regulations or when the corresponding legal conditions are met.
Furthermore, the agreement includes measures related to administrative simplification to expedite registration with the Federal Taxpayers Registry (RFC, for its acronym in Spanish) and the issuance of the advanced electronic signature; continued improvements to optimize processing times for refunds of favorable tax balances; observance of the principle of proportional taxation; the non-imposition of penalties when it is evidenced that institutional system failures prevented timely compliance with tax obligations; the promotion of expedited assistance mechanisms for taxpayers affected by temporary restrictions on digital certificates or cancellation of registrations; and the institutional strengthening of the Taxpayer Defense Ombudsman’s Office (Prodecon, for its acronym in Spanish).
The agreement entered into force on the day following its publication in the DOF.
As always, the Tax and Legal professionals of KPMG Mexico are fully available to work together with you to support in the analysis of the potential implications that the implementation of these provisions may have on your company.
