Plan Mexico — Immediate Actions for Investment:

I. Agreement issuing general criteria and guiding operational guidelines for the promotion of productive investment and tax compliance Through Agreement 68/2026, issued by the Secretary of Finance and Public Credit, general criteria and guiding operational guidelines are established that are applicable within the scope of competence of the Tax Administration Service (SAT), for the purpose of strengthening legal certainty, administrative efficiency, and the promotion of productive investment. It is important to note that these criteria are of a guiding and programmatic nature and do not constitute a limitation, waiver, or modification of the powers conferred upon the tax authorities. The most relevant criteria contained in the Agreement are the following: • The tax authority shall observe and promote compliance with international treaties and with the applicable provisions to avoid double taxation; • Priority shall be given to exercising verification powers in a concentrated manner, seeking a single comprehensive review per fiscal year and per taxpayer, and avoiding simultaneous reviews of different fiscal years; • Audits shall observe the principle of non-retroactivity in the application of review criteria and respect for statute-of-limitations periods; • Measures involving the temporary restriction of digital seal certificates and the cancellation of registrations shall be used as last-resort mechanisms, giving preference to preventive or corrective actions and guaranteeing the right to a hearing; • Administrative simplification shall be promoted in order to expedite registration in the Federal Taxpayer Registry (RFC) and the obtainment of the e.firma (electronic signature); • Implementation of improvements to optimize the turnaround times for refunds of favorable balances shall continue; • Where it is established that failures in institutional systems prevented the timely fulfillment of tax obligations, the imposition of penalties attributable to such failures shall be avoided; • Expedited assistance mechanisms shall be promoted for the regularization of taxpayers affected by measures involving the temporary restriction of digital seal certificates (CSD) or the cancellation of registrations; and • The institutional strengthening of the Office of the Taxpayer Defense Attorney (PRODECON) shall be promoted, including the analysis of schemes that would improve its functional and administrative coordination. II. Decree for the Immediate Authorization of Investments The purpose of this Decree is to incentivize investment projects in order to promote economic development, strengthen the competitiveness of the economic sectors, foster job creation, and promote the development of productivity chains, by means of an Authorization that allows for their immediate implementation, at no bureaucratic cost and without prejudice to compliance with the applicable legal provisions. The Decree provides that private investment projects that fall within any of the following categories may apply for the Authorization: • Investments authorized to be developed in a Development Pole for Well-Being, an Economic Development Pole for Well-Being, or a Circular Economy Pole for Well-Being; • Investments equal to or greater than $2,000,000,000.00 (two billion pesos 00/100 M.N.); • Investments in strategic sectors, including: technological infrastructure, data processing centers, textiles and apparel, semiconductor and microelectronics design and manufacturing, automotive and auto parts, medical devices, pharmaceuticals and biopharmaceuticals, aerospace, energy, and chemicals, among others as determined by the Committee. Investment projects in the mining and financial sectors are expressly excluded from the Decree, as are those that constitute public or mixed investment. The Decree creates the National Digital Investment Window as the sole digital platform for the application, management, and follow-up of the Authorization and of the procedures associated with investment projects. Likewise, the Presidential Office for the Promotion of Investments is created, charged with verifying compliance with requirements, submitting applications to the Investment Committee, and providing guidance and support to investors. The Investment Committee shall be composed of the heads of the Secretariats of Finance and Public Credit, of Environment and Natural Resources, of Energy, of Economy, of Anti-Corruption and Good Government, and the Agency for Digital Transformation and Telecommunications. That Committee shall be the body responsible for granting the Authorization. The Authorization must be issued within the 30 business days following the submission of the application and shall be valid for one year, renewable up to two times for equal periods, provided that the project shows at least 90% of the progress committed for the corresponding period. Authorized projects may begin their development immediately. During the term of the Authorization, the procedures included therein must be resolved by the competent authorities within a maximum of 60 business days following compliance with the requirements. In the case of investment projects that do not have an Authorization but are processed through the Window, the authorities must resolve them within a maximum of 90 business days; otherwise, they shall be deemed authorized (affirmative administrative silence). It is relevant to note that the procedures excluded from the scope of this Decree are those relating to tax, customs, financial, banking, credit, savings, and financial innovation matters, which must be carried out in accordance with the ordinary procedures. Finally, the Investment Committee must be established and issue its rules of operation and functioning within the 30 calendar days following the entry into force of the Decree. Likewise, the Agency for Digital Transformation and Telecommunications must issue the National Model for the Standardization of Investment Procedures within the following 30 business days. The publications described constitute the first concrete regulatory actions of Plan Mexico with respect to administrative simplification, digitalization of procedures, and promotion of productive investment. It is relevant for taxpayers and investors to assess the scope of these instruments in light of their particular operations and projects, in order to take advantage of the simplification benefits that are established. VWYS has a Tax team available to help you analyze the effects of this reform and its application in each particular case. We hope this note is useful to you, and for more information or clarification of any matter, the contact details of our experts are provided below: Alejandro Torres, Partner:+52 (55) 5258 1072 | ajtorres@vwys.com.mx Luis Enrique Torres, Partner:+ 52 (55) 5258-1072| ltorres@vwys.com.mx Miguel Angel Chinchilla Ayala, Associate:+ 52 (55) 5258-1072| mchinchilla@vwys.com.mx

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