Background on Key Figures and Relevance
In January 2018, during the administration of former Mexican President Enrique Peña Nieto, the Mexican government signed a Government Guarantee to provide broad tax exemptions for the FIFA and all related entities involved in organizing the 2026 FIFA World Cup. This guarantee, applicable not only to FIFA but also its subsidiaries, associates, members, suppliers, contractors, individuals, and any third parties connected to the World Cup organization, waived federal and local taxes along with eliminating control and administrative processes until 2028.
Current Administration’s Adjustments
Under the current administration led by President Claudia Sheinbaum, these extensive tax benefits have been limited. The Secretaría de Hacienda y Crédito Público (SHCP) clarified that these benefits now only apply to direct participants in organizing and hosting the 2026 FIFA World Cup, releasing certain formal payment, transfer, retention, collection, and payment obligations outlined in fiscal laws.
However, entities not directly included in the enabling norm of the Federal Income Tax Law (LIF) 2026 that participate in games and events on national territory must pay the Income Tax (ISR).
These limitations on the Government Guarantee’s application were achieved through agreements, avoiding any litigation or controversy resolution methods.
Collaboration and Transparency
The SHCP, led by Edgar Amador, has maintained working tables with FIFA and FEMEXFUT in coordination with other authorities since the beginning of President Sheinbaum’s term.
For transparency, the federal government has made public three documents related to fiscal exemptions and control waivers for the 2026 World Cup:
- Interinstitutional Agreement: Facilitates compliance with regulations and non-tariff restrictions in the temporary import of goods for the FIFA 2026 Cup.
- Temporary Import Rule: Includes a simplified procedure, no payment of customs duty (DTA), and the use of a non-manifest format valid until December 2026 for authorized individuals by FIFA Mexico.
- Enabling Norm in LIF 2026: Releases fiscal obligations for subjects participating in the FIFA 2026 World Cup, with the tax authority issuing control rules for this measure’s application until December 2026.
The Government Guarantee also states that “Mexico guarantees that the provisions contained in this Government Guarantee are legally binding and fully valid.” However, the full guarantee has not yet been made public.
