Executive answer
The First Amendment Resolution to Mexico’s 2026 Miscellaneous Tax Resolution was published July 9, 2026. On July 17, amendments to several exhibits were published, including Exhibits 1, 2 and 3. For transfer pricing, the correct analysis is not “the annual rules changed,” but whether a particular rule, form, format or criterion changes a specific duty.
The filter compares old and new text, reads transitory provisions, confirms the effective date and maps entities and procedures. Many changes may have no direct impact; others affect an adjacent process. Documenting “no impact” is as important as activating an action.
Verification cutoff: August 2, 2026. The resolution and exhibits were reviewed against available SAT and Official Gazette publications. Check later corrections or amendments.
Timeline
Record December 28, 2025 for the original rules, initial exhibit dates, July 9 for the resolution and July 17 for amended exhibits.
Do not assume every item begins July 17.
Main document
Read amendment articles and transitory provisions. Mark additions, reforms and repeals, then search dependencies with transfer pricing.
Do not filter only by exact phrase.
Exhibit 1
It contains official forms. Check whether a group format changed and requires a new version.
Update templates only where relevant.
Exhibit 2
It contains tax procedures. Compare forms by number, name, authority, channel, deadline, requirements and documents.
A renumbered reference can break a checklist even where substance changes little.
Exhibit 3
It compiles criteria on improper tax practices. Verify additions, removals or changes and status. Do not call them legislation.
Assess services, materiality and other related transactions.
Relevance filter
Level one is direct mention. Level two is a procedure used by tax. Level three is a filing or datum using related-party information. Level four is unrelated.
Give a reason for each classification.
Request a before-and-after analysis to turn the first amendment and its exhibits into actions only where entities, data, procedures or evidence are truly affected.
Text comparison
Use a controlled diff against the official source. Review words, references, deadlines, authorities, channels and transitory provisions. Do not rely on a commercial summary.
A comma may be immaterial; a new reference may not be.
Before-and-after table
Include source, location, prior text, new text, type, effective date, taxpayer, process, impact, action, owner and evidence.
A second reviewer approves high-impact changes.
Effective date
Transitory provisions can specify a date, transition or later application. Record it per row.
Do not apply a change retroactively by mistake.
Open procedures
Identify filed, in-preparation and planned requests. Decide which version and channel apply and preserve evidence.
Do not restart a procedure without transition analysis.
Internal procedures
Update manuals, RACI, calendar and links. Mark version and date.
Remove obsolete copies from shared folders.
Adjustments
Check whether forms or rules concerning notices, amended returns or adjustments changed. If not, record the conclusion.
Do not infer a technical change from an unrelated exhibit.
APAs
Search references to advance rulings and the applicable form. Compare requirements and channels. Assess cases in progress.
Do not announce impact where another subject changed.
MAP
Confirm procedural changes and treaty interaction. Do not combine MAP and APA.
Preserve treaty deadlines.
ISSIF and SIPRED
Check whether July exhibits changed relevant formats. If Exhibits 18 and 19 were not included, do not assume they changed.
Monitor later publications.
Criterion 44/ISR/PI
Verify its presence and text in the applicable Exhibit 3. PT-098 analyzes it. This article only records amendment impact.
Avoid duplicate content.
Portal and Gazette sources
SAT facilitates access; the Gazette establishes publication. Retain both links and the PDF where available.
If the portal updates silently, the Gazette reconstructs history.
Advance versions
Compare advance and definitive text. Log differences. An advance version does not replace evidence of publication.
Report the actual date.
Systems impact
Where a format or field changes, assess the ERP, tax engine, repository, calendar and controls. Test before filing.
Do not leave adaptation to the deadline.
Data impact
Define the new datum, source, owner, frequency and validation. If it already exists, confirm quality.
Avoid unreviewed manual entry.
Evidence impact
A form may request different documents. Update index, format and retention. Do not create evidence retroactively.
Assign an owner.
Entity impact
Not every company files the same procedures. Cross-check regime, duty, transaction and status.
The map prevents irrelevant alerts.
Communication
Send an alert with change, date, affected users, action and source. For no impact, publish a short note.
Avoid “everything changed.”
User testing
Ask the person executing the procedure to follow the update in a dry run. Capture questions and time.
A correct memo can fail operationally.
Implementation control
Every action has owner, date, evidence and reviewer. Close only with proof: template, capture, training or receipt.
“Noted” is not closure.
Overinterpretation risk
The amendment may be broad, but the article separates facts from inference. Cite exactly what changed.
If no impact was identified, say so.
Warning signs
Warnings include an advance version, missed exhibit, mixed dates, claims without comparison, treating a criterion as law, system changes before effectiveness or unreviewed open procedures.
Correct before execution.
Checklist
Confirm resolution, exhibit, PDF, prior text, new text, transitory provision, effective date, form, entity, process, data, evidence, system, owner and test.
Record source and date.
Illustrative example
A company prepares a ruling request. The team sees the amendment, compares the Exhibit 2 form, confirms a documentation change, updates the index and conducts a dry run. Other forms are unchanged and marked no impact.
The alert remains scoped.
Regulatory Change Brief product
The brief includes timeline, comparison, filter, entity matrix, actions, evidence and exhibits. It separates legal, procedural and no-impact items.
Brevity comes from analysis, not omitted sources.
Next amendment
Monitor the SAT microsite and Gazette. When a second resolution appears, repeat the method and preserve history.
Do not mix regulatory batches.
Quarterly evidence
The regulatory owner certifies that affected procedures use the correct version and samples one completed file. Any exception receives a remediation date and responsible person.
This confirms that the change moved beyond the comparison table.
Verifiable comparison method
Download both versions from official sources and convert content into a comparable format while preserving originals. A diff tool locates changes, but a person reads the complete paragraph, heading, references and transitory provisions. Record formatting false positives.
For exhibits containing procedures, compare every field: who files, purpose, location, timing, requirements, additional information, resolution and follow-up. A table showing only new words may miss the operating effect.
A second person reproduces material changes from the PDFs. If the reviewer cannot find them, the alert is not ready.
Procedures in progress
Create an inventory with procedure number, entity, start date, stage, version used, next action and owner. For every change, decide whether it applies to filed requests, new requests, supplemental information or later periods only.
Do not alter a submitted package without support. If the portal requests new information, retain a screen capture, date and communication. Escalate differences between the published form and system behavior.
For multiyear rulings or APAs, keep a transition file explaining why some documents followed one version and later documents another.
Manual and training impact
Locate every internal reference to a rule number, form, exhibit, date or link. Update procedures, RACI matrices, calendars, instructions, templates and onboarding materials. Display validity and version in the header.
Train only affected users with practical cases. Then run a short test or walk-through; attending a session does not prove execution. Archive attendance, material and result.
Portal control
Portals can change fields, validations or routes without the user understanding the basis. Before a critical date, test access, signature, permissions, file size, format and receipt. Maintain support and contingency contacts.
Do not share credentials. Assign roles and backups. An exhibit amendment does not remove last-minute technical risk.
Indirect-impact review
A change outside the transfer pricing chapter can alter input data through electronic invoicing, accounting, partner identification, signatures or channels. Ask which inputs the process receives and which outputs other returns consume.
Classify an indirect impact only where the chain is demonstrable. Do not expand the analysis to the entire resolution without reason.
Evidence of no impact
Where a rule or exhibit does not affect the group, record the source, reviewed scope, reason and approver. Examples include an entity outside the population, an unused procedure or an unchanged format.
This prevents repeated reopening and supports reconsideration if the perimeter changes.
Post-implementation review
Thirty days later, sample updated procedures or controls. Confirm version, data, documents, approval and receipt. Record defects and root cause.
If there has been no first use, schedule the review for the expected date. A control existing only in a manual is still untested.
Minimum amendment file
Keep the official PDF, related exhibits, comparison table, transitory analysis, affected population, decisions, system changes and tests in one folder. Add the receipt or first procedure completed under the new version. The index should distinguish official material, internal interpretation and implementation evidence.
Where external advisers participate, archive dated comments and scope, but assign the decision to an internal owner. Advice does not replace evidence that the procedure was updated and used correctly.
Tax committee escalation criteria
Escalate a change of treatment, possible lost deadline, inconsistency between portal and form, multi-entity impact, significant cost or disputed interpretation. The committee receives alternatives, probability, exposure, recommendation and decision date—not a collection of documents without a conclusion.
Purely editorial changes can close with the process owner. Proportional escalation protects committee attention for material decisions.
Quarterly closure control
At quarter-end, reconcile the amendment register to system tickets, procedures and completed filings. Confirm that every material action has evidence, an approver and an effective date. Separate work delayed by interpretation, systems, data or resources and assign an interim measure.
The regulatory owner signs the cutoff and retains a list of reviewed publications with no impact. When the next amendment appears, the team starts from this baseline and assesses the incremental change without losing earlier decisions. Sample one completed action to confirm that documentation and actual execution agree.
Conclusion
The first 2026 amendment requires granular reading. The date in the title does not say what transfer pricing must change.
A before-and-after table with effective date and owner turns a publication into precise execution and prevents overreaction.
Request a Regulatory Change Brief to filter the first 2026 amendment by procedure, entity, data, evidence and action.
Verified official sources
- SAT, 2026 tax rules microsite.
- Official Gazette, amended exhibits published July 17, 2026.
- Official Gazette, July 17, 2026 edition.
- Mexican Chamber of Deputies, current Federal Tax Code.
Verification closed on August 2, 2026. Check later publications and applicable transitory provisions.