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Mexico: General criteria and operational guidelines for tax compliance

Effective May 5, 2026

May 18, 2026

The Ministry of Finance and Public Credit (SHCP) on May 4, 2026, published general criteria and operational guidelines for tax compliance to be exercised by the Tax Administration Service (SAT), including:

  • Observing and promoting compliance with international treaties and applicable provisions intended to prevent double taxation for the benefit of taxpayers
  • Exercising tax audit powers in a concentrated manner, seeking a single comprehensive review per tax year and taxpayer through the analysis of representative samples, while avoiding simultaneous reviews of different tax years except when legal provisions or particular circumstances require the exercise of additional powers
  • Carrying out audits and other tax enforcement actions in accordance with the deadlines, procedures, and requirements established under tax legislation
  • Observing 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
  • Using temporary restrictions on digital seal certificates and the cancellation of registrations only as mechanisms of last resort, prioritizing preventive or corrective actions and guaranteeing the right to be heard
  • Expediting registration with the Federal Taxpayers Registry (RFC) and the issuance of the advanced electronic signature through administrative simplification
  • Optimizing processing times for refunds of favorable tax balances
  • Observing the principle of proportional taxation
  • Refraining from imposing penalties when it is evidenced that institutional system failures prevented timely compliance with tax obligations
  • Promoting expedited assistance mechanisms for taxpayers affected by temporary restrictions on digital certificates or cancellation of registrations
  • Strengthening the Taxpayer Defense Ombudsman’s Office (Prodecon) institutionally

The guidelines became effective on May 5, 2026.

Read a May 2026 report prepared by the KPMG member firm in Mexico

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The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act upon such information without appropriate professional advice after a thorough examination of the particular situation. KPMG LLP does not provide legal services.

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