On September 8, 2026, the Federal Executive submitted to Congress the 2027 Economic Package which includes the General Economic Policy Criteria, the Federal Revenue Law (LIF) bill, the Expenditure Budget Proposal and several tax reform initiatives.
Broadly, the package seeks to strengthen tax collection, improve the traceability of transactions and combat tax evasion and avoidance on several fronts. Although no new general taxes are proposed, several measures could change the effective tax burden, deduction timing, withholdings and the control obligations of certain taxpayers.
The bills are subject to the legislative process, so this analysis should be read as a preliminary review of the issues worth addressing before the 2026 year-end close.
General Economic Policy Criteria
The proposed macroeconomic framework anticipates real GDP growth of between 1.5% and 2.5% with inflation of 3.0% at the close of 2027 and a 3.2% annual average. The estimated exchange rate is 18.0 pesos per dollar at year-end, the 28-day Cetes rate 6.0% nominal and the average price of the Mexican crude mix 61.8 dollars per barrel during the year.
Federal Revenue Law
The capital repatriation program would be reactivated with a 7.5% rate, half the rate applicable in 2026. The tax would be paid on the total amount of the funds returned, without deductions, within the 15 calendar days following the repatriation. The funds must be returned no later than December 31, 2027 and invested in the country for a minimum period of three years.
The annual income tax withholding rate on capital generating interest in the financial system would drop from 0.90% to 0.68% during 2027. The monthly surcharge rate for deferrals would remain at 1.38%, with rates of 1.42%, 1.63% and 1.97% for installment payments depending on their length.
For 2027 only, the bill adds a tax incentive for initial public offerings allowing a 10% income tax rate on gains from the sale of shares, provided the issuer's market value does not exceed 50 billion pesos.
It also proposes an option for taxpayers under the Simplified Trust Regime (RESICO) to calculate VAT by applying a 7% rate on the consideration actually collected, through definitive monthly payments and without the traditional crediting mechanism.
Gasoline and diesel marketers would pay IEPS excise tax when they sell more fuel than they purchased in the same month, effective July 1, 2027.
The bill keeps the incentive to regularize tax debts for taxpayers with income of up to 300 million pesos in 2025, applying 100% of fines, surcharges and enforcement costs. The application must be filed no later than October 31, 2027 and payment made before December 31 of that year.
Income Tax Law
The bill adds a new Chapter X to Title II, called "Mechanism for controlling authorized deductions and tax losses", applicable to Mexican-resident legal entities with taxable income above 50 million pesos in the fiscal year.
The mechanism sets a minimum tax base through limits on authorized deductions and on the use of tax losses. Deductions would be capped using factors of 0.9900 or 0.9667 depending on their level relative to taxable income, and the remainder could be applied over the following 20 fiscal years under Article 78-B.
Article 78-C would limit the use of tax losses to 50% of taxable profit for the year, determined after applying the deduction limit. In the 2027 provisional payments, factors of 1.0658 or 2.6162 would apply to the profit coefficient, in addition to the 50% cap on loss utilization.
Excluded from Chapter X would be, among others, coordinated entities, the primary sector, maquila operations, taxpayers in bankruptcy, insurance institutions and legal entities with fewer than five fiscal years since their registration with the RFC.
Other relevant measures include deducting advance payments for services and leasing as the service is received or the period elapses, the deductibility of payments abroad only in the year the payment is made and the withholding remitted, and reducing the limit on deductible net interest from 30% to 20% of adjusted taxable profit.
The bill proposes eliminating the Optional Regime for Corporate Groups with the group unwinding as of January 1, 2027 and specific deadlines to remit the deferred income tax.
In capital increases from debt capitalization, only the principal actually capitalized would increase the CUCA and the proven acquisition cost of shares. In addition, the UFIN for the year would be reduced by non-deductible items and by expenses that fail to meet deduction requirements.
Simplified Trust Regime
For legal entities, RESICO would cease to be mandatory and become an optional regime with an income threshold rising from 35 to 50 million pesos and with doubled maximum investment deduction rates.
For individuals, the income limit would rise from 3.5 to 5 million pesos and re-entry to the regime would be allowed from the following year when the limit is met and the taxpayer is current on obligations. For agricultural, livestock, forestry and fishing activities, the exempt amount would rise from 900 thousand to 1 million pesos.
At Baker Tilly Mexico we are ready to support the analysis of these bills, the quantification of their impact and the definition of compliance and tax planning measures for 2027.
This document is for informational purposes only and does not constitute tax advice. The provisions discussed correspond to bills subject to discussion and possible amendment in Congress. Information updated as of September 9, 2026.
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