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ARTICLE · 17 APRIL 2026

The System for Securing Tax Debts Contested by Taxpayers Made More Flexible

Meet the legal professionals at Foley & Lardner LLP's Mexico office, including Roberto Arena Reyes Retana, Aldo Mendoza, and Patricio Sandoval. Each attorney brings specialized expertise to serve clients across various practice areas and industries.

MexicoTax
The System for Securing Tax Debts Contested by Taxpayers Made More Flexible El sistema para garantizar créditos fiscales impugnados por los contribuyentes se flexibiliza
On April 9, 2026, a crucial amendment to Mexico’s Federal Tax Code (CFF) was published, restoring taxpayers’ ability to choose the type of tax guarantee that best suits their needs when securing tax liabilities and thereby avoiding collection actions by the tax authority while any defenses filed are being processed. This gives taxpayers back control over the protection of their interests while litigation regarding tax debts is ongoing.
Under Mexican tax laws, taxpayers challenging tax debts assessed against them by the tax authorities—and to prevent collection actions (seizure) by the tax authority while those defenses were pending—had the right to offer any of the guarantees provided for by law, as they saw fit. Until 2025, taxpayers were free to choose the type of tax guarantee, provided they complied

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