Decree of Amendments and Transitory Provisions to the 2027 Income Tax Law (LISR)

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As of November 13, 2026, the Federal Executive published in the morning edition of the Official Gazette of the Federation (DOF) the Decree amending, adding, and repealing various provisions of the Income Tax Law (Ley del Impuesto sobre la Renta - LISR) and issuing transitory provisions, forming an integral part of the economic and tax package applicable starting in the upcoming fiscal year.

The most relevant aspects of this official publication include:

1. International Tax Audits, Transfer Pricing, and Economic Substance

The incorporated amendments strengthen control mechanisms over cross-border and related-party transactions, aligning domestic regulations with international transparency standards:

  • New Obligations in Intercompany Transactions: Supporting documentation and informative disclosure requirements for transactions carried out with foreign-resident related parties are clarified and expanded, demanding greater detail regarding functions performed, assets utilized, and risks assumed.
  • Strengthening of the Business Purpose Criterion: Verification parameters are tightened to validate the materiality and economic substance of corporate restructurings and payments made abroad, conditioning their deductibility on demonstrating a quantifiable economic benefit.

2. Authorized Deductions and Corporate Tax Regime

The decree introduces technical adjustments that directly impact the determination of the taxable base for legal entities under the general regime:

  • Deductibility Limits and Requirements: New clarifications are established regarding the deduction limit for net interest expenses, alongside adjustments to formal tax substantiation requirements (CFDI) for payments made through third parties and specialized services.
  • Updating of Special Regimes: Structural adjustments are made to income accumulation and deduction rules applicable to specific sectors, aiming to close tax avoidance gaps and standardize administrative interpretation criteria.

3. Transitory Provisions and Transition Timelines

To ensure an orderly transition toward the new operational rules, the decree includes a dedicated section of transitory provisions:

  • Phased Entry into Force: Although the general effective date of the decree begins on January 1, 2027, specific transitional deadlines are set for adapting accounting systems, updating notices before the Federal Taxpayer Registry (RFC), and filing informative returns corresponding to prior fiscal years.
  • Legal Certainty for Ongoing Operations: Applicable rules are outlined for tax treatments initiated prior to the reform, safeguarding acquired rights and defining transition criteria for pending tax loss carryforwards.

Summary of Operational Impact










Aspect

Details of Published Information
DOF ReferenceDecree by the Presidency of the Republic (Published on 11/13/2026, Code 5803758).
Regulatory FrameworkIncome Tax Law (LISR) and Transitory Provisions.
ScopeStructural reforms to ISR determination rules, deduction requirements, international tax auditing, and 2027 transition standards.
Fiscal EffectEffective starting January 1, 2027, requiring preventive review of corporate structures, intercompany agreements, and deductibility policies.

Visit the following link to consult the official publication in the Official Gazette of the Federation:

https://dof.gob.mx/nota_detalle.php?codigo=5803758&fecha=13/11/2026#gsc.tab=0