What changes?
Chapter X of the Income Tax Law (LISR) is created (arts. 78-A to 78-F).
Applies to legal entities with revenues > 50 million pesos (MDP) that determine taxable profit.
Limit on deductions: 99% if they are ≤96.67% of revenues; 96.67% if they exceed that threshold.
Limit on tax losses: only 50% of the taxable profit can be reduced.
Remaining amounts are applied in the following 20 fiscal years.
Who does it affect?
Companies with revenues > 50 million pesos (MDP).
Corporate groups.
Companies with recurring losses.
Companies with deductions close to 100%.
Status: Initiative, pending approval.
What changes?
RESICO individuals: limit increases from 3.5 to 5 million pesos (MDP).
RESICO legal entities: limit increases from 35 to 50 million pesos (MDP); optional regime.
Investment deductions for RESICO legal entities: computer equipment at 100%, furniture at 50%, etc.
ROGS repealed: deferred tax must be paid no later than December 31, 2027.
Primary sector exemption: increases from 900,000 to 1,000,000 pesos.
Who does it affect?
Micro and small businesses.
Individuals with revenues between 3.5 and 5 million pesos (MDP).
Legal entities with revenues between 35 and 50 million pesos (MDP).
Corporate groups that were taxed under ROGS.
Primary sector.
Status: Initiative, pending approval.
What changes?
Net interest deduction limit: decreases from 30% to 20% of adjusted taxable profit.
Payments abroad: deductible only if the consideration is paid and the withholding tax is remitted.
Advances for services and leases: deductible in the fiscal year in which they are received.
CUCA: interest and VAT on capitalized liabilities are not included.
Capital repatriation: 7.5% rate.
Withholding for digital platforms: 2.5% for legal entities; 20% without RFC (Tax ID).Incentives from Plan México and Development Hubs.
Who does it affect?
Highly leveraged companies.
Companies with payments abroad.Companies that capitalize debt.
Individuals and legal entities with funds abroad.Digital platforms.
Status: Initiative, pending approval.
Contact
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