Tax | Pérez-Llorca, Despacho de abogados https://www.perezllorca.com/en-mx/practices-and-sectors/tax/ Pérez-Llorca es un despacho de abogados independiente dedicado al asesoramiento jurídico de empresas, tanto nacionales como extranjeras, en los principales ámbitos del Derecho español Fri, 24 Apr 2026 15:44:36 +0000 en-US hourly 1 https://www.perezllorca.com/wp-content/uploads/2024/05/favicon-3-32x32.png Tax | Pérez-Llorca, Despacho de abogados https://www.perezllorca.com/en-mx/practices-and-sectors/tax/ 32 32 Proposal for Tax Reform: Inheritance Tax and Tax on High-Net-Worth Individuals https://www.perezllorca.com/en-mx/news/legal-briefing/proposal-for-tax-reform-inheritance-tax-and-tax-on-high-net-worth-individuals/ Fri, 24 Apr 2026 15:44:36 +0000 https://www.perezllorca.com/?post_type=actualidad&p=107754 The bill proposes amendments to the Income Tax Law, the Social Security Law, the Value-Added Tax Law, and the Tax Coordination Law. Among the most significant measures are the creation of a wealth concentration tax applicable to net assets exceeding 100 million pesos, with progressive rates ranging from 2% to 6%; the elimination of the […]

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]]> The bill proposes amendments to the Income Tax Law, the Social Security Law, the Value-Added Tax Law, and the Tax Coordination Law. Among the most significant measures are the creation of a wealth concentration tax applicable to net assets exceeding 100 million pesos, with progressive rates ranging from 2% to 6%; the elimination of the full exemption on inheritances, taxing amounts above 14 million pesos at rates of 10% to 18%; and the introduction of an exit tax on unrealised capital gains.

The proposal also includes anti-abuse measures aimed at ensuring transparency regarding controlling beneficiaries and the oversight of trust arrangements, as well as an annual tax on the ownership of luxury goods. Of the revenue generated, 60% would be allocated to funding a universal health insurance programme, while the remaining 40% would be channelled to a fund for the National Care System and climate mitigation projects. The bill remains subject to debate and approval by the Congress of the Union as part of the applicable legislative process.

Consult the full content of the Legal Briefing here.

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]]> Fourth Preliminary Version of the First Resolution Amending the Miscellaneous Tax Resolution for 2026 https://www.perezllorca.com/en-mx/news/legal-briefing/fourth-preliminary-version-of-the-first-resolution-amending-the-miscellaneous-tax-resolution-for-2026/ Mon, 20 Apr 2026 19:33:38 +0000 https://www.perezllorca.com/?post_type=actualidad&p=107605 Through the addition of the 27th Transitory Article to the current Miscellaneous Tax Resolution, specific rules are set out to allow taxpayers who initiated tax interest guarantee proceedings between 1 January and 10 April 2026 to opt into the new flexible regime introduced by the amendment to Article 141 of the Federal Tax Code. The […]

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]]> Through the addition of the 27th Transitory Article to the current Miscellaneous Tax Resolution, specific rules are set out to allow taxpayers who initiated tax interest guarantee proceedings between 1 January and 10 April 2026 to opt into the new flexible regime introduced by the amendment to Article 141 of the Federal Tax Code. The Resolution distinguishes between two scenarios: taxpayers who have not yet received a favourable decision regarding the guarantee offered, and those who already have a previously established guarantee.

In both cases, a written request must be submitted to the competent Decentralised Tax Collection Administration within 30 calendar days of the Decree’s entry into force, with the tax authority having a maximum of 20 business days to issue a ruling. It is worth noting that the replacement of previously established guarantees will not interrupt the stay of the administrative enforcement proceedings, nor will it give rise to additional requirements on the part of the tax authority.

Consult the full content of the Legal Briefing here.

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]]> Amendment to Article 141 of the Federal Tax Code https://www.perezllorca.com/en-mx/news/legal-briefing/amendment-to-article-141-of-the-federal-tax-code/ Mon, 13 Apr 2026 18:27:02 +0000 https://www.perezllorca.com/?post_type=actualidad&p=107464 The amendment eliminates the requirement for taxpayers to demonstrate their financial capacity in order to justify the selection of a guarantee mechanism other than the deposit certificate, instead recognising the right to freely choose from a flexible set of options with no mandatory order of preference. This aims to strengthen legal certainty and reduce the […]

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]]> The amendment eliminates the requirement for taxpayers to demonstrate their financial capacity in order to justify the selection of a guarantee mechanism other than the deposit certificate, instead recognising the right to freely choose from a flexible set of options with no mandatory order of preference. This aims to strengthen legal certainty and reduce the scope for discretion on the part of the tax authority.

In addition, the Decree establishes a transitional regime allowing taxpayers whose guarantee proceedings were initiated between 1 January 2026 and the effective date of the amendment to opt into the new regime, provided they expressly request this within 30 calendar days.

Consult the full content of the Legal Briefing here.

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]]> Administrative Justice Reform https://www.perezllorca.com/en-mx/news/legal-briefing/administrative-justice-reform/ Mon, 30 Mar 2026 16:21:19 +0000 https://www.perezllorca.com/?post_type=actualidad&p=107099 The reform introduces several amendments aimed at improving the efficiency of administrative litigation proceedings. Key changes include the promotion of digital justice through electronic filings and notifications, as well as an increase in the monetary threshold for summary proceedings to cases not exceeding 15 times the annual value of the UMA, including straightforward tax rulings […]

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]]> The reform introduces several amendments aimed at improving the efficiency of administrative litigation proceedings. Key changes include the promotion of digital justice through electronic filings and notifications, as well as an increase in the monetary threshold for summary proceedings to cases not exceeding 15 times the annual value of the UMA, including straightforward tax rulings and tax refund matters. The reform also establishes new procedural deadlines, such as six months for the resolution of summary proceedings, fifteen days for motions, and five days as a general deadline, and expands the jurisdiction of the Federal Court of Administrative Justice to hear challenges against decisions issued by the Mexican National Customs Agency. Additionally, it regulates the circumstances under which compensation may be claimed for gross misconduct by the tax authority. The proposal will now be reviewed by the Senate as part of the legislative process.

Consult the full content of the Legal Briefing here.

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]]> Proposed Amendment to Article 141 of the Federal Tax Code https://www.perezllorca.com/en-mx/news/legal-briefing/proposed-amendment-to-article-141-of-the-federal-tax-code/ Fri, 20 Mar 2026 20:45:29 +0000 https://www.perezllorca.com/?post_type=actualidad&p=106656 The proposed amendment seeks to maintain a flexible set of guarantee mechanisms with no mandatory order of preference, eliminating the current requirement for taxpayers to demonstrate their financial capacity in order to justify the use of a mechanism other than a deposit certificate. It also expressly recognizes the right of taxpayers to freely choose the […]

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]]> The proposed amendment seeks to maintain a flexible set of guarantee mechanisms with no mandatory order of preference, eliminating the current requirement for taxpayers to demonstrate their financial capacity in order to justify the use of a mechanism other than a deposit certificate. It also expressly recognizes the right of taxpayers to freely choose the applicable guarantee mechanism, removing the obligation to evidence the inability to access alternative options. These changes aim to strengthen legal certainty and reduce the scope for discretion by the tax authority, while preserving the obligation to guarantee the tax interest in accordance with the law.

Additionally, the proposal provides that guarantee proceedings initiated between January 1, 2026, and the effective date of the amendment may be subject to the new regime, provided that taxpayers expressly request its application within 30 calendar days following its entry into force.

Consult the full content of the Legal Briefing here.

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]]> New SAT transparency guidelines for tax audits in 2026 https://www.perezllorca.com/en-mx/news/legal-briefing/new-sat-transparency-guidelines-for-tax-audits-in-2026/ Wed, 07 Jan 2026 19:05:30 +0000 https://www.perezllorca.com/?post_type=actualidad&p=103607 On January 5, 2026, the SAT published new guidelines aimed at strengthening transparency, legal certainty and proportionality in tax audit procedures. Key measures include the publication of the 2026 Master Plan, limiting audits to one per taxpayer, requesting information through representative samples, and prioritizing audits involving high-risk tax practices. In addition, the guidelines seek to […]

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]]> On January 5, 2026, the SAT published new guidelines aimed at strengthening transparency, legal certainty and proportionality in tax audit procedures. Key measures include the publication of the 2026 Master Plan, limiting audits to one per taxpayer, requesting information through representative samples, and prioritizing audits involving high-risk tax practices.

In addition, the guidelines seek to unify audit criteria nationwide and shorten the timeframes for refunds of unduly paid taxes. As a result, the 2026 tax year will be particularly relevant for taxpayers, who will need to reinforce their supporting documentation and adopt preventive strategies to manage tax risks effectively.

Consult the full content of the Legal Briefing here.

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]]> Miscellaneous Tax Resolution for 2026 https://www.perezllorca.com/en-mx/news/legal-briefing/miscellaneous-tax-resolution-for-2026/ Mon, 29 Dec 2025 18:41:28 +0000 https://www.perezllorca.com/?post_type=actualidad&p=103296 On December 28, 2025, the Miscellaneous Tax Resolution for 2026 was published in the Official Gazette of the Federation, together with its Annexes 1, 4, 5, 6, 8, 15, and 25. Key developments include new provisions applicable to the Simplified Trust Regime (RESICO), changes to the tax mailbox system and the requirements to obtain a […]

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]]> On December 28, 2025, the Miscellaneous Tax Resolution for 2026 was published in the Official Gazette of the Federation, together with its Annexes 1, 4, 5, 6, 8, 15, and 25. Key developments include new provisions applicable to the Simplified Trust Regime (RESICO), changes to the tax mailbox system and the requirements to obtain a positive tax compliance opinion, as well as restrictions on the automatic refund of income tax balances in favor.

The Resolution also sets forth rules for informative returns of digital platforms, administrative facilities, tax regularization programs, and various tax incentives, including those related to the “Plan Mexico” strategy and the Economic Development Poles for Welfare, as well as a special tax regime applicable to the 2026 FIFA World Cup.

Consult the full content of the Legal Briefing here.

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]]> Pérez-Llorca promotes 12 new partners https://www.perezllorca.com/en-mx/news/press-release/perez-llorca-promotes-12-new-partners/ Mon, 15 Dec 2025 12:12:01 +0000 https://www.perezllorca.com/?post_type=actualidad&p=102788 These appointments strengthen the Administrative, Competition, Corporate, Finance, Tax and Regulatory practice areas The firm has also promoted five lawyers from Spain and Colombia to counsels José Luis Romeu will take over the London office of the firm in the first quarter of 2026 Pérez-Llorca today announced the promotion of twelve professionals to partner in […]

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  • These appointments strengthen the Administrative, Competition, Corporate, Finance, Tax and Regulatory practice areas
  • The firm has also promoted five lawyers from Spain and Colombia to counsels
  • José Luis Romeu will take over the London office of the firm in the first quarter of 2026

    • Pérez-Llorca today announced the promotion of twelve professionals to partner in recognition of their track record, commitment, technical excellence and contribution to the growth of the firm. This move bolsters the firm’s leadership and commitment to developing talent in its various offices. Specifically, the new partners are based in the Madrid, Mexico City and Bogotá offices and will strengthen different strategic practice areas for the firm.

    The Pérez-Llorca professionals who will become partners as of 1 January 2026 are:

    • Melchor Álvarez de Mon (Corporate, London)
    • Antonio De Lisi (Corporate, Mexico City)
    • Iciar de Lorenzo (Corporate, Madrid)
    • Francisco Gómez (Corporate, Madrid)
    • Eugenio Marín (Finance, Madrid)
    • Ángel Martín (Corporate, Madrid)
    • Patricio Martínez (Competition, Mexico City)
    • Enrique Muñoz (Regulatory, Mexico City)
    • Antonio Ruiz (Tax, Madrid)
    • Paola Valderrama (Corporate, Bogotá)
    • Belén Wert (Administrative, Madrid)
    • Yi Zhou (Tax, Madrid)

    In addition, the firm has promoted Daragh Brehony (Litigation and Arbitration, Madrid), Eva del Amo (Real Estate, Madrid), Antonio García (Real Estate, Madrid), Nuria García (Real Estate, Madrid) and María Camila Parra (Real Estate, Bogotá) to counsels.

    These appointments reflect Pérez-Llorca’s objective to drive internal growth, recognise in-house talent and strengthen its leadership structure in the face of current and future challenges in the legal market.

    “We thank these professionals for their commitment, effort and dedication, and we are confident that, with the drive of this new generation of partners, our ability to serve our clients and our global reach will be further strengthened,” said Pedro Pérez-Llorca, Senior Partner of Pérez-Llorca.

    London Office

    After seven years at the helm of the London office, the first opened by Pérez-Llorca in foreign territory, Álvaro Ramírez de Haro will hand over the reins to José Luis Romeu, a partner who has been working there since the beginning of 2024.

    Ramírez de Haro will return to Madrid, where he will continue to work closely with the London office through his work with major international funds and firms.

    Likewise, Ander Valverde, a partner based in London since 2022, who has combined his responsibility for the Finance team in Spain with the development of the firm’s debt practice in London, will return to Spain in April 2026, where he will continue to coordinate the Finance practice in Madrid and remain linked to the London office through the firm’s clients in this key financial centre for this practice.

    Pérez-Llorca’s London office has a team of more than 10 people which, alongside José Luis Romeu, includes partners Isabel Villa (Restructuring) and the recently appointed Melchor Álvarez de Mon (Corporate), who joins the team in the British capital to further bolster this location.

    José Luis Romeu joined Pérez-Llorca in 2017 as a lawyer in the Corporate practice and made partner in January 2024. Specialising in commercial law, his career has a strong international flavour as, in addition to an LL.M. in International Business and Economic Law from Georgetown University, he worked in the firm’s London office in 2019 and 2020 and is also a Solicitor of England and Wales.

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    ]]>         The OECD publishes the 2025 update to the OECD Model Tax Convention https://www.perezllorca.com/en-mx/news/legal-briefing/the-oecd-publishes-the-2025-update-to-the-oecd-model-tax-convention/ Wed, 03 Dec 2025 11:11:15 +0000 https://www.perezllorca.com/?post_type=actualidad&p=102256 On 19 November 2025, the OECD published the 2025 update to its Model Tax Convention on Double Taxation. Significant changes have been introduced, including some that could be used by tax administrations and courts in relation to the interpretation and application of existing conventions. The most notable change affects the concept of permanent establishment when […]

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    ]]>     On 19 November 2025, the OECD published the 2025 update to its Model Tax Convention on Double Taxation. Significant changes have been introduced, including some that could be used by tax administrations and courts in relation to the interpretation and application of existing conventions. The most notable change affects the concept of permanent establishment when employees work remotely from their home or similar locations. New cumulative criteria are introduced (50% working time test and commercial motivation test) that companies must consider when assessing permanent establishment status. Important clarifications are also introduced regarding tax residence for the purposes of double taxation agreements signed by the United States, which could affect individuals who are beneficiaries of special tax regimes.

    You can read the full Legal Briefing here.

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    ]]>         2026 World Cup: Why Did Only Mexico Grant a Full Tax Exemption? https://www.perezllorca.com/en-mx/news/interview/2026-world-cup-why-did-only-mexico-grant-a-full-tax-exemption/ Wed, 19 Nov 2025 18:57:43 +0000 https://www.perezllorca.com/?post_type=actualidad&p=101866 In the interview, Rosas explains that Mexico is the only host country to grant a full tax exemption for the tournament, a measure intended to enhance projected economic spillover from tourism and event operations, yet one that raises questions regarding revenue impact and differentiated tax treatment. He also notes that attempting to tax international organizations […]

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    ]]>     In the interview, Rosas explains that Mexico is the only host country to grant a full tax exemption for the tournament, a measure intended to enhance projected economic spillover from tourism and event operations, yet one that raises questions regarding revenue impact and differentiated tax treatment. He also notes that attempting to tax international organizations and foreign service providers could be administratively more burdensome for the State than granting the exemption itself.

    Consult the full content of the interview here.

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