Traceability, deduction limits, and digital control: The 2027 Economic Package strategy to eradicate tax evasion
President Claudia Sheinbaum announced that the essence of the 2027 Economic Package Project will be "to evade tax evasion," strengthening tax mechanisms to eliminate the use of shell companies and tax loopholes without the need to create new taxes.
Curbing shell companies and traceability for "fiscal huachicol"
The federal government focuses its strategy on resolving two of the main sources of revenue leakage for the tax authorities: the proliferation of shell companies and the avoidance of paying the Special Tax on Production and Services (IEPS) through the illegal import of fuels (fiscal huachicol). To combat this latter crime, whose damage to public finances is estimated by the Fiscal Prosecutor's Office at around 600,000 million pesos, the Tax Administration Service (SAT) is preparing a traceability scheme for IEPS. This system will track hydrocarbons from their import, through distribution, to their final sale at service stations.
Key adjustments in the tax scheme: ISR, IEPS, RESICO, and platforms
According to the proposed reforms to the ISR Law and initiatives from the Ministry of Finance and Public Credit (SHCP), tax audits for 2027 will incorporate specific measures in various regimes:
- Limits on corporate deductions (ISR): For companies with revenues exceeding 50 million pesos, authorized deductions are capped (from 96.7% to 99% of accumulated income) and a limit of up to 50% is set for the amortization of tax losses.
- New IEPS scheme for fuels: It is established that distributors, marketers, and service stations will pay the tax on the positive difference resulting from subtracting the liters sold from the liters purchased in the same month.
- Expansion of RESICO: In order to incorporate small and medium-sized businesses into formality, the annual income limit for individuals increases from 3.5 to 5 million pesos, and for legal entities from 35 to 50 million pesos.
- Increased retention for digital platforms: VAT and ISR retentions are expanded for legal entities that commercialize products and services on platforms. These must retain 2.5% of ISR (or 20% if the user does not have an RFC), in addition to 100% of VAT on sales from foreign residents.
- Tax on interest and IPAB fees: The provisional retention by financial entities from individuals for interest decreases from 0.90% to 0.68%, while multiple banking is limited to deducting ordinary IPAB fees up to 75%.
- Repatriation and regularization: The 100% discount on fines and surcharges is maintained for taxpayers with incomes up to 200 million pesos in 2025, and the tax rate for the repatriation of capital destined for Plan Mexico decreases from 15% to 7.5%.
Public expenditure financing and collection targets
This intensive tax enforcement occurs in a scenario where taxes will finance 70% of public spending in 2027, the highest proportion since 1990, compensating for the contraction of oil revenues that generated a shortfall of 170,000 million pesos. The government seeks to continue the record collection of 2025 (487,446 million pesos additional, a real increase of 4.8%) and projects to obtain 496,309 million pesos additional during 2026.
From next+'s perspective, the 2027 Economic Package confirms that tax policy in Mexico has shifted from the creation of new taxes to the use of data intelligence and operational traceability. Closing the net on fiscal huachicol and tightening deductions for large companies not only seeks to cover the gap in oil revenues but also to guarantee resources for 70% of the federal budget. For corporations and digital platforms, the message is direct: automated tax compliance and internal billing audits will be crucial to avoid contingencies in an unprecedented tax enforcement environment.