In brief
On 7 November 2025, the Federal Revenue Law for 2026 (LIF as per its acronym in Spanish language) was published in the Federal Official Gazette (DOF as per its acronym in Spanish language). As part of the LIF for 2026, Article Transitory Twenty-Two establishes a tax incentive for individuals and legal entities whose total revenue in tax year 2024 did not exceed 300 million pesos, consisting on the relief of 100% of fines, surcharges, and enforcement costs for taxpayers who have final or consented tax credits administered by the Tax Administration Service (SAT by its acronym in Spanish) or the National Customs Agency of Mexico (ANAM by its acronym in Spanish), derived from omissions in federal contributions, fines for non-compliance with tax obligations, including those different from payment obligations, as well as countervailing duties.
Taxpayers who were subject to mass tax relief programs or that applied the tax incentive under Article Transitory Thirty-Fourth of the 2025 Revenue Law are excluded from this benefit.
The incentive will be applicable only if taxpayers meet certain conditions, including the following:
- Have tax assessments corresponding to tax year 2024 or earlier.
- File the corresponding returns and pay the tax assessments in a single installment before 31 December 2026.
- Amend detected irregularities during verification powers within the legal deadline, or withdraw defense measures in the case of final tax credits, not later than 31 December 2026.
- For fines for obligations different from payment obligations, the incentive will be of 90%, conditional on rectifying the omitted obligation.
To access the benefit, taxpayers must submit an application to the SAT no later than 31 October 2026, complying with the requirements established in the general rules. The application will suspend the administrative enforcement procedure without the need to guarantee the tax assessment. The SAT will issue the payment form within 15 calendar days, and the taxpayer must pay it within the same period; failure to do so will render the form null and void, and full payment of the credit will be required.
This incentive does not apply to taxpayers with final judgments for tax crimes or those included in the lists in Articles 69-B and 69-B Bis of the Federal Tax Code. The incentive does not apply to credits that fall under the jurisdiction of the General Administration of Large Taxpayers, or to tax credits passed on to the SAT for collection, with the exception of those passed on by the ANAM.
In the case of tax credits subject to seizure, payment in accordance with this incentive will allow the seizure to be lifted and the assets to be returned. For assessments administered by federal entities, the request must be submitted to the local authority, which will follow the general rules of the SAT. Payment may not be made in kind or by compensation.
The SAT will issue general rules for the application of the incentive. This mechanism seeks to encourage tax regularization by offering the incentive to taxpayers who comply with their obligations within the established deadlines.
Recommendations
Taxpayers whose revenue in fiscal year 2024 did not exceed 300 million pesos and who have final or consented tax credits administered by the SAT or ANAM are advised to analyze the possibility of taking advantage of this tax incentive, considering the requirements and deadlines established. Given the relevance of the incentive and the economic impact it may have, it is suggested that the eligibility analysis and preparation of the corresponding documentation be initiated as soon as possible. We invite you to schedule a meeting with Baker McKenzie's experts to discuss appropriate compliance strategies.
