Permanent Access of the Tax Authorities to Digital Platforms’ Tax Information

Our partners Alejandro Torres and Luis Enrique Torres, together with associate Diego Benítez, authored the article “Permanent Access of the Tax Authorities to Digital Platforms’ Tax Information”, published by The Legal 500, examining the implications of Article 30-B of the Federal Tax Code (CFF) for digital platforms operating in Mexico.

Effective April 1, 2026, the provision requires digital platforms to grant tax authorities permanent, online, real-time access to specified information contained in their systems or records to verify compliance with tax obligations.

The article examines the requirements established under the 2026 Miscellaneous Tax Resolution, including transaction-level information, technical access mechanisms and data retention periods. It also addresses interpretive uncertainties surrounding the meaning of “permanent” and “real-time” access, as well as the legal limits on the information tax authorities may consult.

The authors further explore constitutional considerations relating to the audit powers of the Mexican Tax Administration Service (SAT), implementation challenges for foreign digital platforms and multinational groups, and potential implications for sellers and service providers conducting transactions through digital platforms.

The publication also examines the temporary blocking mechanism applicable in cases of noncompliance and the interpretive questions that remained unresolved as of September 2026.

Finally, the article emphasizes the importance of identifying applicable obligations, limiting access to legally required information, maintaining adequate compliance documentation and implementing reconciliation processes to explain potential discrepancies between platform records and tax information.

Read the full article in The Legal 500.