2027 Economic Package: Fiscal Outlook for the New Fiscal Year.

On September 8, the Federal Executive Branch submitted the 2027 Economic Package to the Congress of the Union, consisting of the Federal Revenue Bill, the bills to reform the Income Tax Law and the Federal Law on Fees, the draft Expenditure Budget, and the General Criteria for Economic Policy.

The message from the authorities is that there will be no new taxes or across-the-board rate increases. A closer look reveals that the trend we have observed for several years continues—namely, a policy of greater control and more aggressive enforcement— this year in particular through a reduction in the scope for deducting and carrying forward losses, stricter limits on interest deductions, and more efficient auditing through the use of artificial intelligence.

Below, we summarize what we, based on our experience, consider most relevant for companies.

First, we present a concise overview of the General Economic Policy Criteria accompanying the initiative, which outline the following projections for 2027.

Important Changes and Modifications.

Companies and Corporate Groups

The package includes several important changes for corporations. First and foremost, we highlight transactions involving taxable income exceeding $50 million, as there is a new mechanism for controlling authorized deductions (Chapter X of Title II of the Income Tax Law). When deductions do not exceed 96.67% of taxable income, the cap is calculated by multiplying them by a factor of 0.9900; when they exceed that percentage, the cap is calculated based on taxable income multiplied by 0.9667. Any unused excess may be carried forward for the next 20 fiscal years. Excluded from this mechanism are coordinated entities, the primary sector, maquila operations (except for domestic sales), bankrupt companies, and companies that have been in operation for less than five years.

Similarly, tax losses from prior years may be carried forward only against 50% of the taxable income for the current year, in exchange for extending the period for carrying them forward from 10 to 20 years, and the limit on the deduction of net interest is reduced from 30% to 20% of adjusted taxable income.

For provisional payments in 2027, the profit coefficient is adjusted by a factor of 1.0658 or 2.6162, depending on each taxpayer’s level of deductions, and only 50% of the provisional taxable income may be reduced for losses.

There are other specific adjustments, such as the elimination of the Optional Regime for Corporate Groups, with mandatory disaggregation effective January 2027 and payment of deferred income tax no later than December 31 of that year; the requirement that the deduction for payments made abroad be contingent upon the actual payment of withholding tax in accordance with Articles 27, section V, and Article 153 of the Income Tax Law (LISR); and technical amendments to the CUCA and CUFIN, among others, to exclude from the former accrued interest and VAT on capitalized liabilities, and to expand the list of non-deductible items to be subtracted in the latter.

RESICO and MSMEs

First, it is worth noting an increase in the threshold established by the regulations for tax filing under the RESICO regime, as it rises from $3.5 million to $5 million for individuals, and from $35 million to $50 million for corporations; additionally, the regime is no longer mandatory and becomes optional for corporations. The rules for re-enrollment or re-entry have been updated for those who have left the regime, provided they are up to date on their tax obligations; the exemption for the primary sector increases from $900,000 to $1,000,000, and the deduction for investments in unspecified activities for corporations increases from 20% to 40%.

The incentives under Plan México are also incorporated into the law through transitional provisions; these include an immediate 100% deduction for investments in new fixed assets and an additional 25% deduction on increases in training or technological innovation expenses, effective through 2030.

Revenue Act and Federal Fees Act

With regard to surcharges, the rate of 1.38% per month on outstanding balances and 2.07% per month for late payments remains in effect; for installment payments under Article 66 of the Federal Tax Code (CFF), the rates range from 1.42% to 1.97% per month, depending on the term.

In contrast, the interest withholding rate for the financial system is being reduced from 0.90% to 0.68% annually. A 10% incentive is also proposed for the sale of shares on the stock exchange in the case of initial public offerings, a six-month period to guarantee tax interests in appeals for revocation—with an exemption if the appeal is solely on the merits— and the continuation of the incentive providing for the full waiver of fines, surcharges, and enforcement costs for taxpayers with 2025 income of up to $300 million who settle their principal debt before the end of 2027.

Under the Federal Law on Fees, notable changes include a 35% increase in the immigration fee for visitors without permission to engage in paid activities, the standardization of consular fees at $1,639.80 (increases of 66% and 153% depending on the type of visa), and a 16% increase in the CNBV’s inspection and surveillance fees. In telecommunications, a 12% reduction in radio spectrum fees is proposed for the most expensive bands compared to the international standard, and in the cultural sector, 53 INAH museums and archaeological sites would no longer charge admission, while other sites would be added to the list of those requiring payment. Minor adjustments are also anticipated to air navigation fees, material extraction fees, and water service fees.

Foreign Trade

The report accompanying the package details the use, between September 2025 and September 2026, of the tariff authority granted under Article 131 of the Constitution: an extension of the regulation on used vehicles; the transition of sugar tariffs from specific to ad valorem rates (156% and 210.44%); an extension of exemptions for the basic goods basket through the elimination of 33 tariff lines, a quota-based tariff for railroad tracks, and the modification of 185 tariff lines to protect domestic industries in chemicals, textiles, and steel. The average TIGIE tariff stands at 10.6%, with an effective tariff rate of just 6.7% paid on 8,183 tariff lines.

Adjustments to IEPS

The VAT would remain at 16%, but the IEPS would undergo three specific changes:

High-calorie foods (275 kcal or more per 100 g): The rate would rise from 8% to 20%, unchanged since 2014.

Alcoholic beverages: The current price-based calculation (26.5%–53%) would be replaced by a mixed system with a fixed fee per liter of pure alcohol.

Products high in sodium (new category): instant soups, cold cuts, canned foods, and sauces would be taxed for the first time, at a rate of about 8%.

Auditing and Oversight

The focus of the tax collection strategy is not a new tax or fee, but rather a continuation of more aggressive tax enforcement. There is talk of granting the SAT explicit authority to use big data analysis and artificial intelligence in electronic audits—a topic that has been discussed in previous fiscal years—which would involve greater adoption of these new mechanisms and technologies in audit procedures, whether through automated cross-checking of CFDI invoices, bank deposits, payroll records, and IMSS records in an automated manner.

Two changes seem particularly significant to us for clients subject to materiality audits: first, the cancellation of CFDI invoices would be limited to the same month of their issuance, closing correction windows; and the accelerated review under Article 49-Bis would be extended to taxpayers whose suppliers from 2024 to 2026 appeared on the list under Article 69-B, even if the taxpayer was never notified. In practice, this shifts part of the risk associated with the transaction with the EFOS to the customer who purchased from it, regardless of the customer’s own conduct.

Real-time reporting requirements would also be added for PACs in the event of anomalous time-clock patterns, along with a tightening of the beneficial owner regime—including harsher penalties and an expanded scope to include trusts and business collaboration agreements—with the possibility of sharing that information with foreign authorities.

This analysis was conducted on the date indicated at the beginning of this document; therefore, the economic package has not yet been approved in its entirety, and there is a possibility that it may undergo changes prior to its publication and entry into force.

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The information contained in this notice does not constitute, nor is it intended to constitute, legal advice on the topics discussed herein. It is provided for general informational purposes only. For advice on a specific matter, please contact us.