January 22, 2026
The Federation Revenue Law for fiscal year 2026 incorporated special tax benefits aimed at certain subjects directly involved in the organization and celebration of the 2026 International Federation of Football Association («FIFA») World Cup, with the aim of facilitating the realization of the event in national territory.
In general, the tax benefits imply the release from compliance with certain tax obligations, including formal obligations, as well as transfer, withholding, collection and full payment of federal taxes set forth in tax laws, thus, a total tax exemption in Mexico, provided that the requirements established in the applicable regulations are met.
For the purposes of its implementation, the Tax Administration Service issued, through Chapter 9.4 of the Miscellaneous Tax Resolution for 2026 («RMF»), the specific rules for the application of these tax benefits. In particular, Rule 9.4.3 expressly delimits its subjective scope.
Therefore, this rule excludes the Income Tax («IT») exemption to foreign resident players, with respect to the income they receive as remuneration and prizes paid by a FIFA Member Association, derived from their participation in the competition and in related events.
Consequently, foreign players who participate in the 2026 FIFA World Cup will not be exempt from IT in Mexico for the remuneration and prizes they receive on the occasion of the event, and must determine and comply with the payment of IT in accordance with Mexican tax legislation, that is, applying the rate of 25% on their gross income or 35% on net income (deductions may apply), in the proportion of games that their national team will play in Mexico. It is important to bear in mind that the application of the 35% rate on net income requires the need to appoint a representative in Mexico.
The exemption from IT will not apply neither to legal entities that are appointed by FIFA as the Host Broadcaster of the event (producer of the content or material subject to rights of transmission, dissemination or commercial exploitation through the media) and to the FIFA Service Providers in charge of coordinating the accommodations, transportation, tour operators, tickets, hospitality services or products and computer solutions of the competition or related events, who in accordance with rule 9.4.3 of the RMF must pay the IT for the income obtained and comply with the relevant formal tax obligations.
In this regard, we consider that there are legal grounds to consider that the tax rules published by the Tax Administration Service that exclude players, the Host Broadcaster and FIFA Service Providers from the IT exemption provided for in the Federal Revenue Law, could have exceeded the limits of what was authorized by the Mexican Congress in the latter law, which can be the subject of a defense.
Notwithstanding the foregoing, it is important to note that the tax burden could also be eliminated or reduced through the application of the treaty for the avoidance of double taxation entered into between Mexico and the country of tax residence of the recipient of the income, provided that the formal and substantive requirements provided for in the treaty itself are met.
Our tax lawyers are at your disposal to support you in the comprehensive analysis of the tax impact, including the determination of the applicable tax rate, the application of international tax treaties and a timely compliance with tax obligations in Mexico, derived from the participation of foreign players and other companies related to the FIFA World Cup 2026.
SINCERELY:
Víctor Barajas
mbarajas@basham.com.mx
Luisa Torres
ltorres@basham.com.mx