On October 11, the reference Resolution was published in the DOF, which came into force on October 14, 2024. The main rules that we consider most important that were modified, as well as the non-binding criteria that were added and the regulatory criterion that was modified, were the following:

Gain on the sale of fiduciary stock certificates of a trust that is exclusively invested in a trust dedicated to the acquisition or construction of real estate.
Cases in which a group of people does not carry out business activities due to the celebration of an agreement.
Cases in which business activities are not carried out through a trust.
Requirements for investment trusts in energy and infrastructure.
Investment percentage of trusts dedicated to the acquisition or construction of real estate.
Chapter 11.4. Of the Decree granting tax incentives to encourage the use of means of payment (Buen Fin).
VAT withholding by digital intermediation platforms when payments are deposited in accounts abroad.
Non-binding criterion 44/ISR/NV Deduction of expenses for the provision of services. They are not deductible if it is not proven that the service has actually been provided.
Non-binding criterion 12/IVA/NV Acquisition of goods in national territory owned by a resident abroad. Value added tax withholding.
Regulatory criterion 40/IVA/N Digital Services. Definition of intermediation services for the purposes of the provisions of article 18-B,
section II of the LIVA.
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