Executive Report: Tax, Customs & Regulatory Developments in Mexico
Reporting Period: June 20–27, 2026
Mexico’s tax and regulatory landscape delivered several developments this week that demand immediate attention from corporate leadership. The Mexican Tax Administration Service (SAT) significantly intensified its enforcement actions against shell companies, the United Kingdom officially joined the Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CPTPP), creating new trade opportunities, and hundreds of IMMEX programs are now at risk of cancellation.
If your organization relies on suppliers, conducts cross-border operations, or manages inventory under customs programs, the events that unfolded between June 20 and June 27, 2026 have direct operational and tax implications. This report provides a comprehensive overview of the key developments.
Weekly Agenda
Topics Covered in this Report
SAT — Miscellaneous Tax Rules (RMF), CFDI & Shell Company Enforcement
- Fifteenth Advance Version of the 2026 Miscellaneous Tax Rules.
- IEPS diesel tax incentive update.
- Critical enforcement alert regarding 913 shell companies (EFOS) identified during 2026.
CPTPP — United Kingdom Accession
- Effective June 22, 2026.
- New preferential tariff rates.
- Expanded bilateral trade opportunities.
IMMEX — Suspended Programs
- More than 300 companies face definitive cancellation of their IMMEX authorization effective September 1, 2026, due to failure to submit the 2025 Annual Report.
Article 69-B, Case Law & Federal Administrative Court (TFJA)
- Publication of 99 newly presumed EFOS taxpayers.
- Significant judicial precedents issued by the Federal Judicial Weekly Report (SJF).
- TFJA summer recess calendar.
PRODECON, Inventory Controls & Executive Summary
- Annual tax return installment payment alerts.
- Inventory observation deficiencies.
- Executive assessment of the week’s most significant developments.
SAT — Tax Administration
15th Advance Version of the 2026 Miscellaneous Tax Rules (RMF): IEPS Diesel Tax Incentive
What Changed on June 25?
SAT released the Fifteenth Advance Version of the First Resolution Amending the 2026 Miscellaneous Tax Rules (RMF).
The principal amendment establishes a MXN $0.95 per liter reduction to the diesel base price, continuing the progressive weekly IEPS fuel tax incentive framework established under the Official Gazette (DOF) Decree dated December 27, 2016.
Key Regulatory Amendments
Rule 3.16.11 (Amended)
- Confirms the 0.0484 accumulation factor applicable to foreign deposits and investments held at the beginning of fiscal year 2025.
Rule 11.7.3 (New)
- Incorporates the complete diesel base price reduction schedule covering the period from April 1 through June 25, 2026.
Rule 2.12.4 (Repealed)
- Eliminates procedural formalities related to providing guarantees securing federal tax liabilities.
Important Transitional Provision
Taxpayers seeking to benefit from the revised Article 141 of the Federal Tax Code (CFF) (effective April 10, 2026) , must submit a formal written request to the corresponding Regional Tax Administration Office (ADR) within 30 calendar days.
The tax authority must issue its resolution within 20 business days.
SAT–IMCP Joint Alert
Shell Companies (EFOS): 913 Identified in 2026 — Your Supply Chain Is the Primary Risk
During the joint SAT–IMCP press conference held during the week of June 23–27, SAT’s General Administrator of Collections, Gari Flores, issued a warning that drew considerable attention across the tax community.
According to SAT, the number of Companies Issuing Simulated Tax Invoices (EFOS) identified during 2026 has already reached 913 entities, while historical records under Article 69-B of the Federal Tax Code now exceed 14,000 taxpayers.
2026 EFOS Publications
SAT has identified and published 913 active shell companies during the current fiscal year alone.
Historical Registry
The cumulative registry of taxpayers subject to Article 69-B now exceeds 14,000 entities.
Tax Refund Claims
A significant number of individual taxpayers reported tax refunds in their 2025 Annual Tax Returns, signaling a substantial volume of pending refund claims for SAT to process.
Immediate Risk
Organizations that have not thoroughly reviewed their supplier base following the June 15 Article 69-B publication face heightened exposure to:
- Denial of deductible expenses;
- Disallowance of VAT credits; and
- Additional tax assessments arising from supplier validation failures.
Immediate supplier due diligence is strongly recommended.
Ministry of Economy — International Trade
United Kingdom Joins the CPTPP: Mexico Opens a New Trade Gateway
Effective June 22, 2026, the accession of the United Kingdom of Great Britain and Northern Ireland to the Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CPTPP) became effective for Mexico following Mexico’s notification to the Depositary on April 23, 2026.
The CPTPP now encompasses 12 economies across the Americas, Asia, Oceania, and Europe.
2025 Bilateral Trade
Mexico–United Kingdom trade reached approximately USD 6.293 billion in 2025.
The CPTPP framework provides significant opportunities for future trade expansion.
Industrial & Agri-Food Products
High value-added products—including industrial machinery, manufacturing equipment, motor vehicles, and auto parts—will benefit from progressive tariff elimination between both countries.
Priority Sectors Under “Plan México”
The agreement strengthens Mexico’s:
- Automotive sector
- Aerospace industry
- Pharmaceutical industry
through increased foreign investment and technology transfer.
Rules of Origin Accumulation
The CPTPP’s cumulative rules of origin significantly enhance the participation of both Mexico and the United Kingdom in regional and global value chains.
CPTPP Tariff Agreement
Preferential Tariff Schedule: Liberalization Timeline
The Agreement published in the Official Gazette (DOF) on June 22, 2026, updates Mexico’s General Import Duty rates applicable to goods originating in CPTPP member countries, incorporating the United Kingdom.
Effective Since 2025
Goods classified under Section Four are already duty-free, with retroactive tariff elimination.
January 1, 2027
Tariff elimination for products listed in Appendix II and Section Ten, including a broad range of industrial and agri-food products.
January 1, 2029–2030
Tariff elimination extends to products covered under Sections Six and Seven, including products subject to specific rules of origin.
January 1, 2032–2033
Final tariff elimination for products included in Appendix III and Section Eight, completing the full tariff liberalization process between Mexico and the United Kingdom.
Products listed in Appendix I, primarily dairy and sugar categories, require an import quota certificate issued by the Ministry of Economy to qualify for preferential tariff treatment.
Absent such certification, standard LIGIE tariff rates remain applicable.
IMMEX — Critical Alert
More Than 300 IMMEX Programs Suspended: Compliance Deadline Approaching
On June 25, 2026, Mexico’s General Directorate for Trade Facilitation and Foreign Trade published the list of IMMEX programs suspended due to failure to submit the 2025 Annual Report.
The affected companies span multiple industries, including:
- Manufacturing
- Agribusiness
- Electronics
- Automotive
- Textile manufacturing
Critical Dates
- Last Business Day of August 2026
Final deadline to submit the Annual Report and lift the suspension. - Within Two Business Days
The Ministry of Economy will reinstate the IMMEX authorization upon verification of compliance. - September 1, 2026
Definitive cancellation of IMMEX authorization for companies that fail to regularize their status.
Business Impact
Loss of IMMEX authorization results in the immediate loss of temporary import benefits, preventing companies from importing raw materials, machinery, and production components under the temporary import regime.
The impact extends directly to operational efficiency, customs compliance, and tax competitiveness.
Recommended Action
Verify immediately whether your organization(or any strategic customer or supplier) appears on the published suspension list.
Although regularization remains possible, the available timeframe is limited.
The formal notice will subsequently be published in the Official Gazette (DOF).
SAT — Article 69-B
Article 69-B: 99 Newly Presumed EFOS Taxpayers Published on June 26
Through Official Notice 500-05-00-00-00-2026-16026, SAT’s Central Strategic Audit Administration issued a global notification identifying 99 taxpayers (both individuals and legal entities) presumed to fall under Article 69-B of the Federal Tax Code.
Each taxpayer has 15 business days following the effective date of the final notification to rebut the findings.
Common Findings
SAT identified a recurring lack of:
- Assets
- Personnel
- Operational infrastructure
- Business capacity to perform the services or commercialize the goods supported by the issued CFDIs.
Industries Most Affected
- Construction and civil engineering
- Business consulting
- Wholesale materials distribution
- Information technology services
- Freight transportation
The majority of affected taxpayers are located in:
- Mexico City
- Jalisco
- Puebla
- Tamaulipas
- Sonora
- Nuevo León
Response Period
Taxpayers have 15 business days to submit supporting documentation to the issuing authority.
Failure to rebut SAT’s findings will result in inclusion on the final Article 69-B list published by SAT and the Official Gazette.
Implications for Businesses
Companies that received CFDIs from any of these 99 issuers should immediately evaluate the impact on:
- Income tax deductions
- VAT credits
as provided under the fourth paragraph of Article 69-B of the Federal Tax Code.
Immediate Risk — EFOS Enforcement & Article 69-B
SAT has published 913 shell companies (EFOS) during 2026, including 99 newly presumed EFOS taxpayers notified on June 26. Organizations that have not conducted a comprehensive review of their supplier base remain exposed to significant tax risk.
The joint SAT–IMCP alert confirms that Mexico’s tax enforcement strategy is now driven by data analytics, intensive audit activity, and a zero-tolerance approach toward simulated transactions.
Recommended Action
- Immediately review all inbound CFDIs issued by suppliers.
- Validate supplier status against the SAT’s Article 69-B registry.
- Reinforce supporting documentation demonstrating the business substance of all material transactions.
Immediate Risk — IMMEX Programs Approaching Cancellation
More than 300 IMMEX authorizations have been suspended due to the failure to submit the 2025 Annual Report.
Unless corrective action is taken before the last business day of August 2026, affected companies face permanent cancellation of their IMMEX programs effective September 1, 2026.
Recommended Action
- Confirm your company’s IMMEX status immediately.
- Determine whether any strategic suppliers or customers are included in the suspension list.
- Complete the regularization process before the statutory deadline.
Strategic Opportunity — United Kingdom Joins the CPTPP
The United Kingdom’s accession to the Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CPTPP) creates significant new opportunities for preferential market access involving industrial, agri-food, and other high value-added products.
Mexico’s automotive, aerospace, and pharmaceutical industries are particularly well positioned to benefit from expanded investment opportunities, deeper regional value chains, and preferential tariff treatment beginning June 22, 2026.
Recommended Action
- Review tariff classifications applicable to UK-related transactions.
- Assess eligibility under the revised Rules of Origin.
- Incorporate the published tariff elimination schedule into medium- and long-term supply chain planning.
Technical Action Items — RMF Updates, Installment Payments & Judicial Criteria
Organizations should closely monitor the implementation of Rule 11.7.3 if diesel fuel forms part of their operating cost structure.
Tax advisors should also verify that individual taxpayers who elected to pay their 2025 Annual Income Tax liability in installments remain fully compliant prior to the September 30 deadline.
Additionally, recently published judicial precedents regarding corporate tax domicile and death certificates as evidentiary support should be incorporated into litigation strategies before SAT and the Federal Administrative Court (TFJA) whenever applicable.
Special attention should also be given to procedural deadlines during the TFJA’s July recess period, as judicial filing deadlines continue to run despite reduced in-person operations.
Executive Perspective
The developments observed during the week of June 20–27, 2026 reinforce a clear trend in Mexico’s tax and customs environment: enforcement is becoming increasingly technology-driven, data-centric, and risk-based.
For multinational organizations, proactive governance now requires more than technical tax compliance. It demands continuous supplier due diligence, real-time customs data validation, strategic monitoring of international trade developments, and rigorous documentation capable of supporting every material transaction.
Organizations that strengthen these governance processes today will be substantially better positioned to mitigate audit exposure, preserve tax certainty, and capitalize on emerging trade opportunities under Mexico’s evolving regulatory framework.