The joint Finance and Legislative Studies committees of the Senate approved the 2027 fiscal package opinions on October 21, 2026, which include limits on ISR deductions for companies with revenue above 50 million pesos and the forgiveness of SAT penalties and surcharges.
The legislative path began on October 14, when the Chamber of Deputies approved the reform to the ISR Law and a reservation by Ricardo Monreal that eliminated the 300 million peso cap for accessing the Fiscal Regularization Program. The Senate endorsed the texts without changes in committee, and the floor vote remains the final step. For Mexico, the package projects revenue of 10.6 trillion pesos, domestic borrowing of 1.7 trillion and a deficit of 3.9% of GDP. The Consejo Coordinador Empresarial (CCE) is holding talks with the SAT so that the Senate incorporates reservations, according to Expansión.
The new LISR chapter establishes that companies with accumulated revenue above 50 million pesos and more than five years in the RFC may deduct up to 96.67% of their revenue; if their deductions are already below that threshold, the limit is 99% of deductions. The non-deducted amount is carried forward for up to 20 years, and the amortization of tax losses is limited to 50% of taxable profit. The Asociación Mexicana de la Industria Automotriz (AMIA) warned that the 96.67% cap restricts cash flow, creates disproportionality in provisional payments and detaches the taxable base from contributive capacity, according to Expansión.
The fiscal regularization, endorsed in the Chamber of Deputies on October 14, forgives 100% of penalties, surcharges and execution expenses, but requires payment of the tax owed in a single installment before December 31, 2027. The CCE described the measure as progress and argued, in Expansión, that the reduction of debts reaches between 50% and 60% of the total amount. The next step is the vote on the Senate floor, where the business community is seeking reservations for low-margin companies. As a result, companies will prepare their 2027 returns with a different calculation of deductions, provisional payments and tax debts.
This article was written with the assistance of artificial intelligence from verified sources and reviewed by a human editor before publication.