On September 8, 2026, the Federal Executive Branch submitted to the Chamber of Deputies the Tax Reform initiative for Fiscal Year 2027, which includes the proposed Federal Revenue Law for Fiscal Year 2027, as well as proposed amendments to the Income Tax Law, the Federal Duties Law, and the Customs Law, along with new legislation on the digital economy and cadastral harmonization, among others. The most relevant provisions are summarized below.
I. Amendments to the Income Tax Law
1. New control mechanism for authorized deductions and tax losses (also “NOLS”) (Articles 78-A to 78-F)
- A Chapter X is added to Title II of the Income Tax Law, applicable to corporations resident in Mexico that obtain taxable income exceeding USD $2.95 million1 and determine a taxable profit for the fiscal year.