“MASTER PLAN 2025”
Dear clients and friends:
In recent days, the Ministry of Finance and Public Credit and the Tax Administration Service (SAT) presented the 2025 Master Plan.
Through the aforementioned Plan, the aforementioned agencies of the Federal Executive seek – giving continuity to the past administration – to reaffirm their commitment to republican austerity, financial and fiscal discipline, and the frontal combat against tax evasion.
Regarding the various actions contained in the Plan, it would be worth highlighting the following:
Simplification and Digitalization of Procedures
• Reduction of Requirements:
o Simplification of the registration procedures for the RFC and obtaining the e-signature, benefiting people and companies.
Strengthening Taxpayer Service
• New facilities in the Simplified Trust Regime (RESICO):
o 100% exemption from ISR for the primary sector up to $900 thousand pesos.
o Elimination of the obligation to submit the annual declaration.
o Inclusion of members of cooperatives and credit unions in the regime.
Fiscal Regularization Program 2025
• Facilities for taxpayers with income of up to $35 million pesos:
o 100% reduction of surcharges, fines and execution expenses when correcting tax debts.
• Pre-filling of Declarations:
o Available for companies in the primary sector, Coordinated Regime and Optional Group of Companies Regime.
• Update of Information Declaration Platforms:
o Online presentation of the Multiple Informative Declaration, Operations with Third Parties, Multi-IEPS, among others.
Use of Technology for Fiscal Surveillance
• Application of analytical techniques and statistical learning models to detect irregularities, identify “invoicing companies” and analyze
fiscal behaviors.
• Monitoring of requests for atypical VAT, IEPS and ISR refunds.
• Coordination with authorities such as UIF, IMSS, STPS and INFONAVIT.
• Supervision in sectors with high risk of evasion.
Operations Against Smuggling and Control in Foreign Trade
• Actions to combat:
o Abuses in IEPS and VAT certifications.
o Improper use of benefits from free trade agreements.
o Incorrect tariff classification and customs valuation.
o Omission of VAT withholding by foreigners without permanent establishment.
Strategic Litigation and Fight against Corruption
• Strengthening judicial processes in collaboration with the Attorney General’s Office to prosecute crimes such as tax fraud, smuggling and issuance of false receipts.
• Publication of rules and regulatory criteria in the Official Gazette of the Federation to combat aggressive tax practices.
• Increased training and supervision of officials to guarantee professionalism and transparency.
As final comments, it is important to highlight that:
Yo. The focus on sectors with a high risk of evasion suggests a tightening of oversight. It would be useful to explore how this measure could lead to arbitrary actions towards taxpayers, affecting trust between them and the tax authority, especially in the context of recent judicial changes that could influence control and supervision mechanisms.
ii. The intensification of these actions, in conjunction with the recent reform of the judiciary, could lead to an increase in arbitrary actions towards taxpayers, especially if sufficient counterweights are not guaranteed to protect their rights in the process; Therefore, it is vitally important that there be an impartial judicial system that balances the fight against evasion with respect for individual guarantees, and
iii. This strategy, without a doubt, raises questions about how respect for taxpayers’ rights is guaranteed,
especially in light of the recent judicial reform, which could modify the balances in protection against actions
arbitrary.
iv. It should be taken into account the facility that the authority is granting so that taxpayers with incomes of less than $35 million pesos can access a 100% reduction in surcharges, fines and execution expenses when correcting tax debts – in a diverse bulletin we will send you all the
information related to this option.
As always, the lawyers who make up Valdés, Morán y Asociados, S.C., remain at your service and available to provide you with the necessary support in relation to the information provided here.
