Introduction
The 2026 Economic Package proposes a series of amendments to Mexico’s Federal Tax Code (CFF) to intensify the fight against “factureras” – entities engaged in issuing false tax receipts – and enable the application of preventive detention.
Expert Commentary
“This is a far-reaching reform, signaling an all-out effort against factureras,” said Luis Pérez de Acha, a tax law specialist.
Constitutional Background
In 2024, the Constitution was amended to include false tax receipt activities in the list of offenses subject to preventive detention, effective January 1st of this year. However, Pérez de Acha explains that although the term “false tax receipts” was included in the Constitution, its definition wasn’t clearly established in the Federal Tax Code.
Proposed Amendments
The Secretariat of Treasury and Public Credit (SHCP) now aims to precisely define false tax receipts as those that do not cover genuine, existing transactions, true acts, or real legal actions.
Under the reform, the Tax Administration Service (SAT) can conduct home visits when there are reasonable grounds to suspect false billing, aiming to verify if tax receipts correspond to genuine transactions.
Legal Proceedings
Pérez de Acha elaborates that the SHCP would file a complaint or report with the Attorney General’s Office to initiate an investigation, which would then be presented to a judge. If the judge finds sufficient evidence to link the accused to the crime, preventive detention would be ordered.
In addition to preventive detention, the tax authority would also have the power to cancel digital seals of emitters and recipients of false tax receipts.
Penalties
Both penal and administrative sanctions would apply to those who either issue or receive false tax receipts, according to the proposed amendments.
Targeting Fiscal Bootlegging
The government also seeks to implement stricter controls within the CFF amendments to combat “fiscal bootlegging,” or illicit tax-related activities.
