The waiver of penalties and surcharges on tax debts approved by the Chamber of Deputies for 2027 is good news for all taxpayers, including large companies with outstanding debts, according to Baker Tilly Mexico.
"It is good news for taxpayers and for the tax authority as well," said the firm's Managing Partner of Legal José Luis Elizondo in an interview. He explained that, if approved by the Senate, the reduction in surcharges and penalties could represent two thirds of the current total of a tax assessment.
That estimate considers an annual surcharge rate of around 18% in 2025 and nearly 25% in 2026.
What changed in the 2027 Revenue Law
The proposal was added as a transitional article of the 2027 Federal Revenue Law and removes the 300 million peso revenue cap for accessing the tax regularization program, as well as the exclusion of matters handled by the SAT's Large Taxpayers General Administration office.
As a result, individuals and companies of any size could request the elimination of penalties, surcharges and collection costs, provided they pay the principal tax adjusted for inflation.
Not a clean slate
Elizondo stressed that this is not a tax amnesty like those of previous years, since taxpayers must still pay the tax and its inflation adjustment. He therefore recommended that those with debts in litigation assess their case before applying for the benefit.
"It is worth it for taxpayers to analyze how much the contingency represents for them," he suggested.
Factors to assess before settling
The specialist recommended reviewing the nature of the dispute (whether it involves a procedural, formal or substantive defect) and whether there is a binding precedent that helps estimate the chances of success.
Taxpayers should also consider the age of the assessment, the remaining procedural time and the uncertainty that the benefit would only apply during the next tax year if approved. With these elements, each taxpayer can decide whether it makes sense for them.
At Baker Tilly, we help individuals and companies analyze their tax contingencies and define the best strategy regarding the 2027 regularization program.
Article published in El Porvenir, with information from El Universal.
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