First Resolution of Amendments to the Miscellaneous Tax Resolution for 2026

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Through the official portal of the Tax Administration Service (SAT), the final document of the First Resolution of Amendments to the RMF for 2026 was released. This instrument consolidates the tax provisions applicable for the current fiscal year, integrating energy stimulus rules, procedural formalities for tax guarantees under the Federal Tax Code (CFF), and accumulation parameters for international investments.

The core points of this tax and customs publication are:

1. General Schedule for the Diesel Tax Stimulus

The resolution officializes the addition of rule 11.7.3. for calculating the base price of diesel regarding IEPS, establishing the reduction per liter that taxpayers may apply during specific periods of 2026:

  • Progressive Scale: The final regulatory text incorporates deductions per liter ranging from 28 pesos during the initial periods of April, moving through rates of 0.60 pesos, 1.03 pesos, 1.04 pesos, and consolidating at 1.05 pesos per liter during June.
  • Fuel Control: The methodology aligns with the guidelines of the Fuel IEPS Decree to mitigate volatility within the cargo transportation supply chain.

2. Transitory Regime for the Substitution of Guarantees (Art. 141 CFF)

The legal framework of the Twenty-Seventh transitory article is defined for taxpayers requiring to comply with the amended tax interest guarantee procedure:

  • Mechanism via Free-Form Written Request: Taxpayers with ongoing procedures or with guarantees already established before the Decentralized Collection Administrations (ADR) have a period of 30 calendar days following the enforcement of the corresponding decree to request the application of the new framework under Article 141.
  • Protection of the Procedure: Requests and the subsequent substitution of assets under procedure sheet 60/CFF of Annex 2 guarantee that the suspension of the administrative execution procedure (PAE) will not be interrupted.

3. Accumulation Parameter for Foreign Interest Income

The amendment to rule 3.16.11. is formalized regarding the obligations of individuals holding capital outside national territory:

  • Operational Factor: The accumulation factor to be applied to the total amount of deposits or financial investments held abroad at the beginning of the fiscal year is set at 0.0484.

4. Structural Changes to Annexes 1 and 2

The text validates and incorporates technical changes concerning the formats and service channels of the tax authority:

  • Annex 1: Update of official approved forms and guides required for customs and tax control submissions.
  • Annex 2: Restructuring of technical tax procedure sheets, regulating asset appraisal documentation and corporate property offerings.

Summary of Operational Impact

Details

Published Information

SAT Reference

First Resolution of Amendments to the 2026 RMF (Compiled).

Energy Change

Consolidation of the reduction schedule for the diesel base price (up to $1.05/L).

Legal Guarantees

Transition rules to Art. 141 of the CFF through procedure sheet 60/CFF.

International Investment

Income tax factor for foreign assets formally established at 0.0484.

For more information, visit the following link:

https://www.dof.gob.mx/nota_detalle.php?codigo=5793101&fecha=09/07/2026#gsc.tab=0

https://www.sat.gob.mx/minisitio/NormatividadRMFyRGCE/documentos2026/rmf/rmf/1aRM_RMF2026.pdf