Mexico: Updates to digital platform and digital services rules
Changes under the First Amendment to the 2026 Miscellaneous Tax Rules
The Mexican tax authorities on July 9, 2026, published the First Resolution of Amendments to the 2026 Miscellaneous Tax Rules (read TaxNewsFlash).
The publication includes updates related to digital platforms, foreign residents providing digital services in Mexico, and certain activities carried out through the internet or digital intermediation platforms.
Withholding relief for digital platforms intermediating air transportation services
The publication incorporates a specific rule allowing digital platforms that provide intermediation services between third parties to avoid income tax and VAT withholdings on payments or consideration received by airlines for national or international air transportation services. The relief applies to Mexican or foreign airlines, with or without a permanent establishment (PE) in Mexico, when the relevant income may not be taxed in Mexico under an applicable tax treaty, or when the airline is a member of the International Air Transport Association (IATA).
For the relief to apply, the airline must provide the platform with its Mexican tax ID or, as applicable, its foreign tax registration or identification number. If the airline does not provide this information, the digital platform would be required to make the corresponding income tax and VAT withholdings.
E-signature certificate for foreign residents providing digital services
The publication also updates the procedure for foreign residents providing digital services in Mexico to obtain or renew their Mexican e-signature certificate. The procedure now applies to both the generation and renewal of the e-signature certificate. In practical terms, this amendment does not create a new substantive tax obligation. Rather, it clarifies that foreign digital service providers may use the relevant procedure not only to generate their e-signature certificate for the first time, but also to renew it when needed.
Monthly reporting of services or transactions carried out
The publication includes formal updates to the way in which certain digital service providers must report information related to the number of services or transactions carried out during each calendar month.
The change does not create a new substantive reporting obligation. Rather, it clarifies that the required information should be provided through the applicable electronic tax return, instead of suggesting a separate informational filing submitted alongside the return. The amendment also updates the reference to the specific excise tax (IEPS) return applicable to games with bets and raffles carried out through the internet or digital intermediation platforms and links this reporting obligation with the corresponding IEPS payment rule.
IEPS payment for games with bets and raffles carried out through digital channels
The publication also updates the reference to the return used to pay IEPS on games with bets and raffles carried out through the internet or digital intermediation platforms. This amendment is mainly procedural, as it updates the name of the return used for payment purposes, without changing the general payment timing or the basic mechanics described in the rule.
It is important to note that for 2026, Mexico has introduced several important changes for digital platforms, such as expanding the withholding tax obligations, issuance of e-invoicing of withholding, and real-time and permanent access to information. For more details read TaxNewsFlash and TaxNewsFlash.
KPMG observation
The amendments to the Miscellaneous rules mainly provide clarifications. However, the new withholding relief for digital platforms that intermediate air transportation services is the most relevant change from a practical and operational standpoint.
Limiting this withholding relief exclusively to digital platforms that intermediate air transportation services raises serious constitutional concerns, as it arbitrarily excludes other platforms that also provide intermediation services under comparable conditions. This differentiated treatment lacks clear and objective justification and may therefore infringe the principles of equality and non-discrimination. Consequently, tax professionals believe there are strong and reasonable grounds to pursue the appropriate legal remedies, with the aim of securing an interpretation and application of the provision that extends the benefit to any digital platform engaged in intermediation services, and not solely to those operating in the air transportation sector.
For more information, contact a KPMG tax professional in Mexico:
Antonio Zuazua | azuazua@kpmg.com.mx
Jose Alberto Gonzalez | jagonzalez@kpmg.com.mx