October 15, 2026.
The Chamber of Deputies approved the amendments to the Income Tax Law and the Federal Revenue Law for 2027. Both bills were referred to the Senate, which must act on them no later than October 31. If the Senate approves them without amendments, they will be sent to the Executive Branch for enactment; if it amends them, they will be returned to the Chamber of Deputies. They will take effect on January 1, 2027, only after their publication in the Official Gazette of the Federation.
The report on the Income Tax Law was approved without any of the more than two hundred reservations submitted being adopted, so the content we analyzed in our September article is confirmed in its entirety up to this point. In the Revenue Act, however, an amendment approved during the plenary session introduced the most far-reaching change of the entire process: the elimination of the income cap for eligibility for the tax regularization program by 2027.
Below, we share a summary of the most significant proposals in this reform. On our blog, you can find a more detailed analysis of each point—an analysis we conducted when the 2027 Economic Package proposal was released.
Companies and Corporate Groups
The draft bill provides for new mechanisms to control deductions under Chapter X of Title II, a 50% limit on the carryforward of losses, a reduction in the net interest cap from 30% to 20%, an adjustment to the profit coefficient for provisional payments in 2027, the requirement that deductions for payments to foreign entities be contingent upon the payment of withholding tax, the deduction of services and advance payments up to the fiscal year in which they are accrued, and the elimination of the Optional Regime for Corporate Groups.
The combined effect would amount to a minimum tax of approximately 1% of revenue for companies that exceed the threshold, applied to monthly cash flow starting in January 2027.
RESICO, the primary sector, and digital platforms
The bill provides for new thresholds under the Simplified Trust-Based Tax System, the option to pay value-added tax at a rate of 7% without claiming credits, and an increase in the exemption amount for the primary sector to 1 million pesos.
For digital platforms, the withholding requirement would be extended to legal entities. Without a Federal Taxpayer Identification Number, the withholding would be 20% of income tax and 100% of value-added tax.
Revenue Act: Changes to the Legislative Process
Through a legislative provision, the 300 million peso cap on eligibility for the tax regularization program was eliminated. This program provides for a 100% reduction in fines, surcharges, and enforcement costs related to final tax assessments. This means that the benefit would be available to taxpayers of any size.
Other proposals
The capital repatriation rate would remain at 7.5%.
The annual withholding tax on interest would drop from 0.90% to 0.68%.
For more information and personalized advice on how these changes may affect your company’s operations, please contact us using the contact information provided below.
Pablo del Valle
Vega, Guerrero & Asociados
pablo.delvalle@vegaguerrero.com
The information contained in this note does not constitute, nor is it intended to constitute, legal advice on the topics discussed herein. It is provided solely for general informational purposes. For advice regarding a specific case, please contact us.
