Published
November 03, 2026
The U.S. Chamber is encouraged that the Mexican Senate made amendments to the corporate tax reforms it approved as part of the 2027 Federal Revenue Law, which now returns to the Chamber of Deputies for review. While this is a positive signal, the amendments do not fully address concerns that the legislation, as drafted, would have significant unintended consequences for law-abiding companies that pay taxes and maintain substantial operations in Mexico.
In a letter sent to Mexican policymakers on October 27th, the Chamber urged modifications that would preserve the government’s anti-abuse objectives while avoiding unnecessary harm to compliant taxpayers, productive investment, employment, and Mexico’s competitiveness. The Chamber remains concerned that the proposed Chapter X deduction and loss cap would operate as a minimum taxable-profit threshold regardless of actual economic profitability, limiting the deduction of ordinary business expenses and restricting the use of tax losses.
The modifications under Article 78-E appear to rely on narrow, sector-specific exceptions rather than a broader, cross-industry solution. While the revised language would exclude certain sectors and situations, it does not address the underlying concerns for large, mature companies operating outside those categories.
As a result, law-abiding companies would remain subject to the proposed deduction and loss cap. If not appropriately modified, this approach could create significant tax uncertainty for U.S.-headquartered companies, increase cash-tax costs, reduce working capital, and adversely affect investment, employment, supply chains, and Mexico’s broader competitiveness. Modifications under Article 78-E need to apply more broadly and should not rely solely on narrow exceptions.
The U.S. Chamber respectfully urges Mexican policymakers to use this opportunity to advance a balanced, workable solution that supports tax compliance while preserving the certainty, transparency, and predictability businesses need to invest, hire, and grow. We stand ready to continue working constructively with the Government of Mexico and others in the private sector to ensure the final package strengthens Mexico’s investment climate and supports shared prosperity across North America.
To read the full letter, click here.
About the author
Neil Herrington
Neil Herrington is senior vice president for the Americas Department at the U.S. Chamber of Commerce. His portfolio includes executive management of the department’s programs, councils, and hemispheric policy initiatives. Herrington also serves as president of the U.S.-Cuba Business Council, the U.S.-Colombia Business Council and the U.S.-Argentina Business Council.
