The 2027 General Economic Policy Guidelines are based on the following macroeconomic projections:

Public Sector Borrowing Requirements (RFSP) are estimated at 3.9% of GDP for 2027, down from an estimated 4.1% at year-end 2026, reflecting the goal of continuing gradual fiscal consolidation. On the revenue side, the SHCP projects total budgetary revenue of approximately 10.64 trillion pesos, with tax revenue reaching a historic high of 15.9% of GDP (roughly 6.26 trillion pesos), representing real growth of 5.9% versus the estimated close of 2026. According to Finance Ministry’s own criteria, this increase would only be partially explained by expected economic growth, meaning a significant portion would depend on the effect of the proposed tax changes and stronger enforcement.

The proposed LISR reform is primarily aimed at combating tax evasion through adjustments to how companies determine their taxable base:

Key incentives are preserved.

• Repatriation of capital: the preferential 7.5% ISR rate (instead of 15%) is maintained, subject to investment and in-country holding requirements of at least three years.
• Tax regularization program: would continue for taxpayers with annual income of up to 300 million pesos, offering a 100% reduction of fines, surcharges, and collection costs (or 90% in certain cases), through a single payment due no later than October 31, 2027.
• Merits-only revocation appeal (recurso de revocación exclusivo de fondo), without the need to secure the tax interest.
• Existing incentives for diesel, biodiesel, agricultural and forestry activities, transportation, production processes, and mining remain in place, as does the 50% toll-fee credit (although the income threshold to access this benefit would drop from 300 to 250 million pesos).

The proposal would extend to legal entities the withholding scheme currently applicable to individuals operating through digital platforms: 2.5% ISR withholding on gross income (20% if no tax ID/RFC is provided), and IVA withholding of 50% or 100%, depending on whether the taxpayer’s registration is provided. The 100% IVA withholding would also extend to foreign residents selling goods within Mexican territory and to providers who receive payment into foreign bank accounts. In addition, platforms’ obligation to report all of their clients to the SAT would be broadened, even in cases where the platform has not processed the payment.

• Reduction of the annual interest withholding rate from 0.90% to 0.68% of the principal generating the interest.
• Substantive restrictions remain in place for credit institutions, insurers (limits on IVA crediting when indemnities are paid through third parties), and IPAB (multiple banking institutions may only deduct one-fourth of their IPAB fees).
• New withholding obligations for crowdfunding institutions: 20% ISR on nominal interest paid and 16% IVA on the nominal value of accrued interest.

The bill contemplates updated fees for government services and for the use of national assets, with notable impacts on sectors such as financial services, telecommunications, water, and maritime activities, along with new billable items arising from recent regulatory changes. The stated objective is to recover the actual cost of the services provided by the authorities, meaning that in several cases the adjustments would exceed inflation.

Although the Federal Government has emphasized that the 2027 Economic Package creates no new taxes and does not raise existing rates, the General Economic Policy Guidelines themselves acknowledge that the projected growth in tax revenue (up to a historic high of 15.9% of GDP ) will depend heavily on stricter control, compliance, and enforcement mechanisms, as well as on combating tax evasion, tax avoidance, and companies that issue invoices for simulated transactions (EFOS).

Several private-sector organizations and analysts share this reading and anticipate a climate of greater scrutiny for taxpayers during 2027:

For companies, this means that, even without changes to the general ISR and IVA rates, the risk of inquiries, information requests, and audit actions by the SAT will increase. It is advisable to prepare for this scenario by reviewing the company’s tax structure, the supporting documentation for deductions, transfer pricing, and compliance with formal obligations, ahead of the proposed provisions taking effect.

Legal Notice and Copyright

The content of this article is for informational and general information purposes only. It does not constitute a legal opinion, personalized advice, or specific tax advice. Consequently, ST STRATEGO assumes no liability arising from the interpretation or use of this document.

Reproduction of this publication in whole or in part, by any means or format, is strictly prohibited without prior, express, and written authorization from the author. Any unauthorized use will be punished in accordance with the Federal Copyright Law and other applicable provisions.

If you would like more information on the information presented here or to learn more about our legal, tax, and foreign trade solutions, please do not hesitate to contact us at info@stratego-st.com.

The 2027 General Economic Policy Guidelines are based on the following macroeconomic projections:

1. GDP growth of between 1.5% and 2.5%.
2. Estimated inflation of 3.0% by year-end.
3. Reference exchange rate of 18.0 pesos per US dollar.
4. Nominal 28-day CETES interest rate of approximately 6.0%–6.1%.
5. Average price of the Mexican crude oil basket of USD 61.8 per barrel.

Public Sector Borrowing Requirements (RFSP) are estimated at 3.9% of GDP for 2027, down from an estimated 4.1% at year-end 2026, reflecting the goal of continuing gradual fiscal consolidation. On the revenue side, the SHCP projects total budgetary revenue of approximately 10.64 trillion pesos, with tax revenue reaching a historic high of 15.9% of GDP (roughly 6.26 trillion pesos), representing real growth of 5.9% versus the estimated close of 2026. According to Finance Ministry’s own criteria, this increase would only be partially explained by expected economic growth, meaning a significant portion would depend on the effect of the proposed tax changes and stronger enforcement.

The proposed LISR reform is primarily aimed at combating tax evasion through adjustments to how companies determine their taxable base:

Key incentives are preserved.

• Repatriation of capital: the preferential 7.5% ISR rate (instead of 15%) is maintained, subject to investment and in-country holding requirements of at least three years.
• Tax regularization program: would continue for taxpayers with annual income of up to 300 million pesos, offering a 100% reduction of fines, surcharges, and collection costs (or 90% in certain cases), through a single payment due no later than October 31, 2027.
• Merits-only revocation appeal (recurso de revocación exclusivo de fondo), without the need to secure the tax interest.
• Existing incentives for diesel, biodiesel, agricultural and forestry activities, transportation, production processes, and mining remain in place, as does the 50% toll-fee credit (although the income threshold to access this benefit would drop from 300 to 250 million pesos).

The proposal would extend to legal entities the withholding scheme currently applicable to individuals operating through digital platforms: 2.5% ISR withholding on gross income (20% if no tax ID/RFC is provided), and IVA withholding of 50% or 100%, depending on whether the taxpayer’s registration is provided. The 100% IVA withholding would also extend to foreign residents selling goods within Mexican territory and to providers who receive payment into foreign bank accounts. In addition, platforms’ obligation to report all of their clients to the SAT would be broadened, even in cases where the platform has not processed the payment.

• Reduction of the annual interest withholding rate from 0.90% to 0.68% of the principal generating the interest.
• Substantive restrictions remain in place for credit institutions, insurers (limits on IVA crediting when indemnities are paid through third parties), and IPAB (multiple banking institutions may only deduct one-fourth of their IPAB fees).
• New withholding obligations for crowdfunding institutions: 20% ISR on nominal interest paid and 16% IVA on the nominal value of accrued interest.

The bill contemplates updated fees for government services and for the use of national assets, with notable impacts on sectors such as financial services, telecommunications, water, and maritime activities, along with new billable items arising from recent regulatory changes. The stated objective is to recover the actual cost of the services provided by the authorities, meaning that in several cases the adjustments would exceed inflation.

Although the Federal Government has emphasized that the 2027 Economic Package creates no new taxes and does not raise existing rates, the General Economic Policy Guidelines themselves acknowledge that the projected growth in tax revenue (up to a historic high of 15.9% of GDP ) will depend heavily on stricter control, compliance, and enforcement mechanisms, as well as on combating tax evasion, tax avoidance, and companies that issue invoices for simulated transactions (EFOS).

Several private-sector organizations and analysts share this reading and anticipate a climate of greater scrutiny for taxpayers during 2027:

For companies, this means that, even without changes to the general ISR and IVA rates, the risk of inquiries, information requests, and audit actions by the SAT will increase. It is advisable to prepare for this scenario by reviewing the company’s tax structure, the supporting documentation for deductions, transfer pricing, and compliance with formal obligations, ahead of the proposed provisions taking effect.

Legal Notice and Copyright

The content of this article is for informational and general information purposes only. It does not constitute a legal opinion, personalized advice, or specific tax advice.

Consequently, ST STRATEGO assumes no liability arising from the interpretation or use of this document.

Reproduction of this publication in whole or in part, by any means or format, is strictly prohibited without prior, express, and written authorization from the author. Any unauthorized use will be punished in accordance with the Federal Copyright Law and other applicable provisions.

If you would like more information on the information presented here or to learn more about our legal, tax, and foreign trade solutions, please do not hesitate to contact us at info@stratego-st.com.