On April 9, 2026, an amendment to Article 141 of the Mexican Federal Tax Code (“CFF”) was published, restoring the traditional framework for securing tax credits after changes introduced earlier this year.
Background
Prior to January 1, 2026, taxpayers in Mexico were allowed to secure tax credits using any of the mechanisms provided under Article
Mexico’s Tax Administration Service (“SAT”) recently published Notice 01/2026, announcing a series of “best practices” that, at least on their face, seek to provide greater transparency, legal certainty, and uniformity in tax audit procedures throughout Mexico during 2026.
Among the most relevant announcements are: (i) the publication of the 2026 Master Plan, “Taxpayer Assistance and
Overview
Mexico’s Federal Revenue Law for fiscal year 2026 (the “Law”) once again incorporates a capital repatriation incentive, offering preferential tax treatment for the return of funds held abroad. While this represents a meaningful opportunity, experience from prior years shows that its proper application requires careful planning, solid documentation, and precise execution to avoid future