New Capital Repatriation Plan: Flexibility for Individuals and Businesses
The Twenty-Fourth Transitory Provision of the 2026 Federal Revenue Law establishes a preferential capital repatriation scheme for individuals and legal entities residing in Mexico, as well as for residents abroad with a permanent establishment in the country.
One of the key points of this program is that the return of funds can be made through related parties. This means that it is not essential that the remitter abroad and the beneficiary in Mexico be the same entity. The regulation allows, for example, a partner who maintains capital abroad to repatriate it and contribute it directly to the company of which they are a member. Similarly, a parent company can channel funds to its Mexican subsidiary.
This provision grants taxpayers greater flexibility in channeling their resources to the country and creates certainty by maintaining the logic of previous regulations, such as the 2017 one. The measure also favors tax planning for business groups, since repatriated funds can be used for productive purposes, such as the acquisition of assets, technological development, or the payment of liabilities, provided the legal requirements are met.
It is essential to keep in mind that, although the scheme is flexible, taxpayers must maintain strict documentary evidence to prove both the relationship between the parties and the specific use of the resources, so that the tax authority can verify compliance with the intended purposes.
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