Executive answer
Mexico’s 2026 Miscellaneous Tax Resolution was published on December 28, 2025. Its exhibits appeared on that date and during January 2026; the first amendment resolution was published July 9 and several amended exhibits on July 17. A responsible transfer pricing review considers rules, exhibits, forms, transitory provisions and the statutes providing context.
The resolution does not replace the Income Tax Law or Federal Tax Code and is not the source of the entire framework. Some provisions regulate form, procedure, notices, documentation or adjustments; other duties remain statutory. The useful task is identifying what changed, what continued, from when, for which entities and which data or process must change.
Verification cutoff: August 2, 2026. Consult SAT’s official microsite and the Official Gazette for later versions and exhibits. This article does not replace the text applicable to a particular act or year.
Publication map
Retain the original resolution, Gazette index, exhibits, first amendment and amended exhibits. Record publication and effective dates under transitory provisions.
Do not work only from a PDF downloaded in January.
Norm hierarchy
Start with the Income Tax Law and Federal Tax Code. Then locate the resolution, exhibits, forms and portal. Escalate any apparent conflict rather than assuming an administrative rule replaces legislation.
Document the statutory basis of each duty.
Relevant-rule inventory
Search documentation, returns, adjustments, APAs, MAP, procedures, information and criteria. Use numbers and terms but read complete context.
Classify direct, indirect or no impact.
Transfer pricing adjustments
Review rules for real, virtual, voluntary, primary, corresponding and secondary adjustments. Identify requirements, year, accounting, returns and notices.
Do not execute a true-up from the study without tax, contract and indirect-tax review.
Notices and forms
For late or corresponding adjustments, review current rules and forms. Confirm method, deadline, authority, documents and receipt.
The form does not replace economic support.
Information returns
Cross-check the DIM appendix, Local File, Master File, CbCR and other filings with legislation. Identify owners, date, language, format and data source.
Do not copy the study without reconciliation.
Request a regulatory crosswalk to turn 2026 rules, exhibits and forms into an entity-level matrix of transactions, dates, data, evidence and owners.
ISSIF and SIPRED
Formats and questionnaires appear in specific exhibits. The 2026 microsite identifies publication dates for Exhibits 18 and 19. Verify year and traceability.
Every answer links to a figure, document and conclusion.
APAs
Cross-check Federal Tax Code Article 34-A, annual rules and the applicable form. Confirm requirements, fees, information and process.
Feasibility still depends on materiality and stability.
MAP and treaties
Annual rules may address procedure, but the treaty governs access and framework. Read both and preserve deadlines.
Do not treat corresponding relief as automatic.
Exhibit 2
Exhibit 2 contains tax procedures and was initially published and then modified in July. Compare the old and new form, transitory provisions and date.
Update checklists and links.
Exhibit 3
It compiles criteria on improper tax practices. Criterion 44/ISR/PI on services appears there. It is an administrative criterion, not a statute.
Quote status accurately and analyze legal basis separately.
Exhibits 18 and 19
They contain 2025 statutory-audit formats filed in 2026. Identify transfer pricing questionnaires and source data.
Do not use another year’s form.
Continuing rules
The same rule number can contain new wording, references or transitory effects. Compare text rather than the table of contents.
Mark no material change where appropriate.
New rules
For every addition, document issue, taxpayer, effective date, process, data and control. Do not issue a general alert where transfer pricing is unaffected.
Separate direct change from dependency impact.
Repealed rules
Confirm whether a duty disappeared, moved or remains statutory. Change process only with support.
Retain the version used for prior years.
Transitory provisions
Read effective date, election, period, migration and prior-rule treatment. Publication and effectiveness can differ.
Record the applicable date on the calendar.
Advance versions
SAT may publish advance versions. Label them and confirm definitive publication before citing as final.
Keep history and access date.
Impact matrix
Fields include source, rule, law, exhibit, topic, prior text, new text, status, effective date, entities, processes, data, evidence, action, owner and due date.
Record “no impact” with a reason.
Operating calendar
Connect the legal date to data freeze, review, approval and submission. Add dependencies between study, ledger and filing.
Do not manage only transmission day.
Data governance
Assign a source system to every field. Validate population, currency, counterparties and method. Maintain a dictionary.
Clear rules do not cure inconsistent data.
Version control
Archive PDF, URL, date, internal hash, comparison and approval. Mark superseded documents.
Prevent one team from using January and another July.
Internal communication
Issue summaries for tax, accounting, legal, treasury and operations. Every alert has an action and date.
Do not forward the entire resolution without filtering.
Compliance rehearsal
Select an entity and trace duty from statute through rule, form, data, evidence and receipt. Repeat for material operations.
The dry run finds broken links and unclear ownership.
Monthly controls
Monitor intercompany transactions, margins, adjustments, evidence and contract changes. Annual rules are executed throughout the year.
Record exceptions and escalation.
Year-end close
Reconcile the study, returns, ISSIF, SIPRED, accounting and electronic invoices. Document legitimate differences.
Do not close until owners sign.
Warning signs
Warnings include citing 2025 rules, ignoring an amendment, confusing exhibits, treating an advance version as final, assuming a rule creates statute, missing transitory provisions or failing to update a form.
Correct before filing.
Checklist
Confirm resolution, amendments, exhibits, law, transitory provisions, rule, form, version, date, entity, transaction, data, owner, evidence and receipt.
Record next review.
Illustrative example
A group prepares a late adjustment. It identifies the rule and form, reconciles the calculation, reviews invoices and return, confirms the transitory provision and assigns submission. It does not merely send the notice.
The file retains the source and receipt.
Regulatory Change Brief product
The brief contains executive summary, change matrix, entity obligations, calendar, data impact, actions and official sources. Every conclusion has status.
It does not turn every tax change into a transfer pricing change.
Continuous update
Review SAT’s microsite monthly and upon a Gazette publication. Compare versions and update after validation.
Retain history for audit.
Executive certification
At each quarter, the regulatory owner certifies which publications were reviewed, which changes affected the group, which controls were updated and what remains open. A second reviewer verifies high-impact items.
The certification prevents silent reliance on a stale consolidated copy.
Annual regulatory workflow
In December, the team creates a controlled copy of the publication and records differences from the prior year. During January, it adds exhibits as they appear, updates the calendar and assigns tasks. Each month it reviews advance versions and Gazette publications; quarterly, it certifies that procedures and templates use the correct version. In July or after an extraordinary amendment, it repeats comparison and testing.
The workflow separates research, decision and implementation. The person detecting a development should not unilaterally change a critical process. Tax interprets, legal validates where needed, the process owner implements and a reviewer confirms evidence.
Keep a search log even where nothing changed. It demonstrates that no alert resulted from review rather than neglect.
Process workshop
Bring together owners of the study, returns, ISSIF, SIPRED, adjustments, APAs and controversies. For each process, walk through rule, input, calculation, approval, output and receipt. Identify where a date, form or field change would break the flow.
Use a real transaction. Trace one intragroup service from invoice and ledger to the DIM appendix and Local File, checking amount, method and counterparty. Then simulate an adjustment and its documents. This reveals dependencies that legal reading alone may miss.
Finish with change, owner, date, system and evidence. No-impact items are documented and closed.
Impact taxonomy
Classify developments as substantive, procedural, documentary, technological, timing or editorial. Substantive changes treatment; procedural changes action; documentary changes requirements; technological changes format or channel; timing changes a date; editorial changes a reference without material effect.
One rule can have several types. The taxonomy determines test depth and approval. An editorial correction can close after review; a substantive change needs analysis, scenarios and executive authorization.
Record exposure from nonimplementation: penalty, rejected procedure, inconsistency, adjustment, lost deadline or operating cost. This prioritizes work beyond publication urgency.
Traceability package
For each material change, archive source, old text, new text, transitory provision, interpretation, affected entities, action, test and approval. Link system tickets, training, updated templates and first execution. A third party should reconstruct why the control changed.
Do not overwrite the prior text; retain it as superseded. If interpretation changes later, add a note and assess transactions executed under the earlier version.
First-use review
The first procedure or return filed under the 2026 resolution or an amendment receives enhanced review. Compare the format, fields, documents, signatures, channel and receipt. Capture portal screens where appropriate and log incidents.
Then add lessons to the standard procedure. Technical acceptance of a filing does not prove every datum is correct; the review covers form and substance.
CFO report
The CFO receives only developments involving exposure, cost or a decision. Present the duty, entities, date, financial impact, action, progress and residual risk. Summarize no-impact updates in an appendix.
Do not claim complete compliance while work remains open. Percentages should reflect completed controls with reviewed evidence. A configured but untested task remains in progress.
Documented review closure
The annual review ends with process-level certification, not with reading the latest bulletin. Each owner confirms the current source, completed action, successful test and evidence location. Tax retains open exceptions and their resolution dates. The next update can therefore start from a verifiable baseline instead of rebuilding the analysis.
Document no-impact conclusions as well. State the population reviewed, exclusion rationale and approver. This negative evidence reduces repeated work and allows the matter to reopen when an entity, transaction or system changes.
The closing memorandum should list unresolved interpretations separately from unfinished implementation. That distinction lets management see whether exposure arises from legal uncertainty, operational delay or both, and assign the right response.
Conclusion
The 2026 resolution is an essential operating layer, but it must be read with statutes, exhibits, forms and amendments. Its complexity requires source and date control.
The best output is not a long summary; it is a matrix stating exactly what each entity must do and what evidence supports it.
Request a Regulatory Change Brief to cross-check the 2026 resolution, amendments, exhibits, legislation and transfer pricing processes.
Verified official sources
- SAT, 2026 tax rules microsite.
- Official Gazette, December 28, 2025 edition.
- Official Gazette, 2026 Miscellaneous Tax Resolution PDF.
- Mexican Chamber of Deputies, current Income Tax Law.
- Mexican Chamber of Deputies, current Federal Tax Code.
Verification closed on August 2, 2026. Check later publications before execution.