Extension of the tax regularisation programme for 2027
As part of the discussions surrounding the 2027 Federal Revenue Law, an amendment has been approved that could represent a significant opportunity for taxpayers to regularise their tax position and address tax contingencies currently under audit procedures or facing outstanding tax contingencies with the Mexican Tax Administration Service (SAT).
The proposal approved by the Senate contemplates the extension of the Tax Regularisation Programme, removing the revenue threshold that previously limited its application to large taxpayers.
With this measure, taxpayers who meet the requirements established by law may be eligible for relief equivalent to 100% of penalties, surcharges and enforcement costs. It is important to note that this benefit would not include the forgiveness of the principal tax liability or inflation adjustments. However, it could still represent a substantial reduction in the cost of resolving certain tax contingencies.
This initiative is particularly relevant for companies currently subject to audit procedures. Depending on the specific circumstances of each case, the scope of the findings issued by the tax authorities, and the procedural stage of the audit, it may be advisable to assess the available options in advance and determine whether voluntary correction or tax regularisation would be an appropriate strategy.
Although the reform must still complete the legislative process before coming into force, this is an opportune time to identify matters that could potentially benefit from this mechanism, while continuing to consider the defence, compliance and remediation strategies applicable to each particular situation.
At Forvis Mazars, we will continue to monitor the progress of this initiative and its potential implications for taxpayers.
Should you wish to understand how this measure may affect your organisation's specific circumstances, our team of specialists would be pleased to review your situation and assess the associated opportunities and risks.
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