More than 55 years ago, Mexico inaugurated the 1970 FIFA World Cup. Now, in 2026, the country is preparing to host the tournament for the third time, alongside the United States and Canada. The most recent World Cup, held in 2022, reached an estimated global audience of five billion people, a figure expected to be surpassed in 2026.

The 2026 World Cup represents a major economic opportunity for Mexico. It is projected to generate more than $2.7 billion in economic activity in Mexico alone and create up to 100,000 temporary jobs. Key sectors, including tourism, hospitality, transportation, and entertainment, anticipate substantial increases in revenue. Against this backdrop, the Mexican government has revisited the tax exemptions originally agreed upon with the International Federation of Association Football (“FIFA”) in 2018, seeking to ensure that a portion of the economic windfall benefits public finances.

To that end, special provisions were incorporated into Mexico’s 2026 Federal Revenue Law, specifically in its Twenty-Fifth Transitory Article, establishing tax measures aimed at facilitating the organization of the World Cup. Broadly speaking, tax relief was approved for parties directly involved in the tournament. However, these incentives will apply only during 2026 and exclusively to those entities participating in the organization and execution of the event, under rules to be issued by Mexico’s tax authority, the Tax Administration Service (“SAT”).

The SAT implemented these provisions through the 2026 Miscellaneous Tax Resolution, particularly Chapter 9.4, which outlines the tax treatment applicable to each category of participant. In general terms, FIFA, its subsidiaries, confederations, and member associations will benefit from the agreed tax exemptions. By contrast, host broadcasters and FIFA service providers will be exempt only from Value-Added Tax (“VAT”) and Excise Tax (“IEPS”), but will remain subject to Income Tax (“ISR”) on revenues derived from the event. Foreign players, in turn, will be required to pay Mexican income tax on base compensation and prize money related to matches played in Mexico, with the Resolution specifying that only the portion of income attributable to matches held in Mexican territory will be considered Mexican-source income.

According to the Mexican government, these measures are designed to ensure that the substantial economic activity generated by the World Cup also strengthens public finances. As stated by the Ministry of Finance, the objective is to “honor international commitments without undermining future tax collection,” while reinforcing the principle of tax equity. The government has made clear its intention to avoid broad, generalized tax exemptions and instead leverage the event to enhance tax revenues.

These measures have generated divided reactions. Critics argue that excluding players from full tax exemptions contradicts the language of the Federal Revenue Law, which grants benefits to all parties who “participate in the organization and staging of the 2026 FIFA World Cup, its matches, and related events.” Under a literal interpretation, this could arguably include players. However, such a reading may be overly rigid and must be balanced against the Mexican State’s sovereign taxing authority. An alternative view holds that such an interpretation is excessively broad. From this perspective, tax exemptions should be construed restrictively, particularly in tax matters, and therefore cannot be automatically extended to any individual linked to the event. Under this reasoning, it could be considered  sound for the SAT to distinguish between those involved in the institutional and operational structure of the event and those who merely earn income within Mexican territory as a result of their professional activities. Accordingly, the imposition of income tax on foreign players represents an ordinary exercise of Mexico’s taxing powers.

Historically, during the World Cups hosted by Mexico in 1970 and 1986, no direct taxation was imposed on athletes, leading some commentators to view the current approach as novel. From a legal standpoint, however, and consistent with constitutional principles of equality, any individual, domestic or foreign, who earns income in Mexico is subject to taxation, in accordance with the constitutional principle of equality, which establishes that anyone who generates income in the country is subject to taxation, regardless of nationality.

In parallel with these tax measures, Mexico has also introduced specific rules in the area of international trade. A reform published on October 21, 2025, establishes a framework to facilitate the temporary importation of goods intended for use in the World Cup and related events. These provisions streamline the entry of technical equipment, staging materials, uniforms, promotional items, and other necessary goods. Authorization may be requested by individuals or legal entities endorsed by the official organizing body in Mexico and able to document their participation in the event. Additionally, goods that are consumed during the event or distributed free of charge for promotional purposes are exempt from the requirement to be returned to their country of origin. This special regime seeks to balance logistical efficiency with fiscal and customs oversight, preventing misuse while providing certainty to both authorities and operators.

In summary, the tax framework adopted by Mexico for the 2026 World Cup establishes a differentiated tax regime that combines measures aimed at facilitating the global sporting event with mechanisms designed to protect tax revenue.