At a glance
#Dates are for an example year end of Dec 31, 2025. Where local law moves a deadline on a weekend or national public holiday to the next working day, the date shown is already moved. Use the Deadlines tool for your own year end and thresholds.
Verified 2026-10-28. Tax authority: Servicio de Administracion Tributaria (SAT). Summaries are simplified; check the linked official source before relying on them.
The law
#Ley del Impuesto sobre la Renta (LISR) arts. 76 fracs. IX, X and XII, 76-A, 179 and 180, plus Reglamento LISR art. 302 and the Resolucion Miscelanea Fiscal (RMF) 2026 rules 3.9.7 to 3.9.18. LISR art. 179 says the OECD Transfer Pricing Guidelines apply for interpretation to the extent consistent with the law and treaties. The tax year is the calendar year.
Documentation
#Contemporaneous TP documentation (art. 76 IX) for taxpayers with related-party transactions, unless prior-year revenue was MXN 13 million or less (business) or MXN 3 million or less (professional services). Art. 76-A returns for taxpayers in CFF art. 32-A (2nd para.) or 32-H I, II, III, IV, VI (for example revenue of MXN 1,103,204,520 or more for 2026, listed companies, foreign residents with a PE): Local File by 15 May, Master File by 31 December of the following year. Annual related-party information return (art. 76 X) by 15 May. All filed electronically in Spanish on SAT forms.
Methods
#Six methods in art. 180. CUP comes first; if it is not appropriate, use the most suitable of the others (resale price, cost plus, profit split, residual profit split, TNMM), with resale price and cost plus preferred. Where there are two or more comparables, the range may be adjusted with the interquartile method (RLISR art. 302). If the taxpayer is outside the adjusted range, the arm's length value is the median.
Penalties
#CFF art. 81 XVII / 82 XVII: MXN 112,750 to 225,500 for not filing, or filing wrong, the art. 76 X related-party information return. CFF art. 81 XL / 82 XXXVII: MXN 226,000 to 321,770 for not filing the art. 76-A Master, Local or CbC returns, or filing them incomplete or with errors (amounts updated 28 Dec 2025). ISSIF failures fall under CFF art. 83 XVII. Omitted tax from TP adjustments attracts the general 55% to 75% penalty plus inflation and surcharges.
Pillar Two
#Mexico has not enacted Pillar Two: there is no IIR, UTPR or QDMTT and no Mexican GloBE filing. It is not listed on the OECD central record of qualified rules (current to 1 May 2026), and the 2027 Economic Package presented in September 2026 does not add one. Mexican entities may still be covered by top-up taxes and GIRs filed in other countries.
Other rules
#APAs under CFF art. 34-A. Maquiladora safe harbour under LISR art. 182. Secondary adjustments: an adjustment can be treated as a deemed dividend (RMF rule 3.9.1.1 lists LISR arts. 11, 140 and 164). Voluntary and compensatory adjustments must follow RMF rules 3.9.1.1 onward. Interest limits: net interest above 30% of adjusted taxable profit is not deductible (LISR art. 28 XXXII), but only where interest accrued in the year exceeds MXN 20 million (shared across group members); interest on debt above 3 times equity is not deductible where the debt is owed to foreign related parties (art. 28 XXVII). CbC: Mexican parent groups with prior-year consolidated revenue of MXN 12,000 million or more; local entities designated by a foreign parent file and are deemed to have given notice by filing (RMF 3.9.10).
Filings and deadlines
#| # | Filing | When | Who | Source |
|---|---|---|---|---|
| 1 | Annual corporate income tax return (declaracion anual) Within the three months after year end (LISR art. 76 V). The tax year is the calendar year, so this is 31 March. No general extension. | 3 months after year end (e.g. Mar 31, 2026) | All legal entities under Title II of the LISR. | Ley del Impuesto sobre la Renta, art. 76 frac. V |
| 2 | ISSIF (Informacion sobre la Situacion Fiscal), includes related-party annexes Filed as part of the annual return (a .sb2x file attached to the annual return, RMF 2.16.1). | With Annual corporate income tax return (declaracion anual) (e.g. Mar 31, 2026) | CFF art. 32-H: prior-year revenue of MXN 1,103,204,520 or more (2026 amount; use the amount in force for the year being reported), listed companies, optional group regime members, state entities, foreign residents with a PE, Mexican companies with foreign transactions (relieved if under MXN 100 million, RMF 2.16.3) and related parties of mandatory dictamen filers whose transactions with that filer exceed MXN 13 million, or MXN 3 million for professional services (RMF 2.16.5). | Codigo Fiscal de la Federacion, art. 32-H |
| 3 | Annual related-party information return (art. 76 X, filed through DIM Annex 9) By 15 May of the year after the tax year (LISR art. 76 X, reformed 2021). Filed through DIM Annex 9 (RMF 2026 rule 2.8.2.1). | Fixed calendar date (e.g. May 15, 2026) | Taxpayers with related-party transactions. Not required if prior-year business revenue was MXN 13 million or less (MXN 3 million for professional services), unless they deal with preferential tax regimes or are hydrocarbon contractors (RMF 3.9.18). | Ley del Impuesto sobre la Renta, art. 76 frac. X |
| 4 | Declaracion informativa local de partes relacionadas (Local File) By 15 May of the year after the tax year (LISR art. 76-A, last paragraphs). Filed on the SAT portal (RMF 3.9.7). | Fixed calendar date (e.g. May 15, 2026) | Taxpayers with related-party transactions that fall in CFF art. 32-A second paragraph (revenue of MXN 2,013,710,870 or more, or listed) or art. 32-H fracs. I, II, III, IV or VI (for example revenue of MXN 1,103,204,520 or more). | Ley del Impuesto sobre la Renta, art. 76-A |
| 5 | Dictamen fiscal (tax audit report with TP annexes) By 15 May of the year after the tax year (CFF art. 32-A). | Fixed calendar date (e.g. May 15, 2026) | Mandatory for entities with prior-year revenue of MXN 2,013,710,870 or more (2026 amount, updated 28 Dec 2025; use the amount in force for the year being reported) or with shares listed on a stock exchange; optional for some smaller taxpayers. | Codigo Fiscal de la Federacion, art. 32-A |
| 6 | Declaracion informativa maestra de partes relacionadas (Master File) By 31 December of the year after the tax year. Group members may file one joint Master File and CbC return (RMF 3.9.9). | Fixed calendar date (e.g. Dec 31, 2026) | Same population as the Local File (CFF arts. 32-A second paragraph and 32-H I, II, III, IV, VI) with related-party transactions. | Ley del Impuesto sobre la Renta, art. 76-A |
| 7 | Aviso of designated CbC filing entity Law: aviso by 31 December of the year after designation (LISR art. 76-A III b). RMF 3.9.10 treats the aviso as given when the designated entity files the CbC return on time, so there is no separate notification in practice. Mexico has no general CbC notification for other entities. | Fixed calendar date (e.g. Dec 31, 2026) | Only a Mexican entity (or PE) designated by a foreign parent to file the CbC report. | RMF 2026, rule 3.9.10 |
| 8 | Declaracion informativa pais por pais (CbC report) By 31 December of the year after the tax year. If the foreign parent's year ends January to May, RMF 3.9.10 sets the last day of the same month in the following year (for example 31 March for a March year end). | Fixed calendar date (e.g. Dec 31, 2026) | Mexican parent of a multinational group with prior-year consolidated accounting revenue of MXN 12,000 million or more, or a Mexican entity designated by a foreign parent. SAT can also request it from a local subsidiary when exchange fails (120 business days to respond). | Ley del Impuesto sobre la Renta, art. 76-A frac. III |
| 9 | Contemporaneous TP documentation (art. 76 IX) No filing date. Must be obtained and kept for each tax year and recorded in the accounts; SAT can only audit it for closed years. In practice prepare it before the annual return and the 15 May filings. | See note | Taxpayers with related-party transactions, except prior-year business revenue of MXN 13 million or less, or MXN 3 million or less for professional services (exception does not apply to preferential regime transactions or hydrocarbon contractors). | Ley del Impuesto sobre la Renta, art. 76 frac. IX |