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Taxes during a Mexican liquidation: the early year end, monthly payments, January returns, the final return and exit by change of residence

Last verified: 2026-10-26 · Status: Stable

When a company enters liquidation its tax year ends that day and a short year return is due within three months; the whole liquidation then counts as a single tax year. The liquidator pays provisional income tax monthly by the 17th, files a return by 17 January for each calendar year the liquidation spans and files the final return within the month after the liquidation ends. A Mexican company that moves its tax residence abroad is treated as liquidated: all its assets are deemed sold at market value and the tax is due within 15 days, through a Mexican representative who is jointly liable.

USD conversions use MXN 18.6638 per US dollar, the US Federal Reserve H.10 noon buying rate in New York for 23 October 2026 (FRED series DEXMXUS), the latest observation available when this page was verified. Mexican tax law uses the Banxico FIX for foreign currency amounts, which differs slightly. Conversions are for orientation only.

Key facts

Corporate income tax rate30 %LISR art. 9, as of 2026-10-26 · in force
Monthly provisional payments during liquidation due by day17 day of following monthLISR art. 12, as of 2026-10-26 · in force
Return for each calendar year in liquidation17 January of the following year LISR art. 12, as of 2026-10-26 · in force
Final liquidation returnWithin the month after liquidation ends LISR art. 12, as of 2026-10-26 · in force
Exit tax on change of residence due within15 daysLISR art. 12, as of 2026-10-26 · in force
Return for the year ended early on entering liquidation3 monthsLISR art. 9; CFF art. 11, as of 2026-10-26 · in force

The rule

1. When a company enters liquidation, merges or splits with the splitting company disappearing, its tax year ends early on that date. In the case of liquidation there is a single tax year for the whole time the company is in liquidation. The tax for the short year is paid by return within three months after the year ends.
Cost to do it: No fee; the cost is the accounting work for a short year closing.
Example: A company enters liquidation on 30 April 2026. Its tax year 2026 runs 1 January to 30 April 2026 and the return is due by 30 July 2026. / Not a monetary rule.Código Fiscal de la Federación (CFF), DOF 31 December 1981 (Chamber of Deputies consolidated text, last reform DOF 9 April 2026), CFF art. 11; LISR art. 9, 1981-12-31 official text · verified 2026-10-26
2. The liquidator files monthly provisional income tax payments by the 17th of the following month until all assets are realized; these exclude assets of establishments abroad. At the end of each calendar year the liquidator files a return by 17 January of the next year, determining the tax for the period from the start of liquidation to that year end and crediting earlier payments. The last return is the return for the liquidation year, which includes foreign establishments' assets and is due within the month after the liquidation ends, even if less than twelve months have passed since the previous return.
Cost to do it: No fee. Each period's tax is at the 30 percent corporate rate on the result (LISR art. 9).
Example: Liquidation starting 1 May 2026 and ending 31 March 2027: monthly payments from May 2026; a return by 17 January 2027 for May to December 2026; a final return by 30 April 2027 for the whole period from 1 May 2026 to 31 March 2027, crediting the January return and monthly payments. / Not a monetary rule.Ley del Impuesto sobre la Renta (LISR), DOF 11 December 2013 (Chamber of Deputies consolidated text, last reform DOF 1 April 2024), Art. 12, first paragraph, 2013-12-11 official text · verified 2026-10-26
3. SAT requires the short year return on entering liquidation, each annual return during liquidation and the final liquidation return to be filed through the standard corporate annual return application for the general regime.
Cost to do it: Free online filing.
Example: The liquidator files the January 2027 return in the same annual return application used for any other year. / Not a monetary rule.Resolución Miscelánea Fiscal para 2026, DOF 28 December 2025 (SAT compilation including the First Amendment, DOF 9 July 2026), Rule 2.8.3.2, 2026-07-09 official text · verified 2026-10-26
4. A Mexican resident company that ceases to be resident in Mexico under the CFF or under a tax treaty is treated as liquidated. All its assets in Mexico and abroad are deemed sold at market value on the date of the change of residence, or at an appraisal by an authorized appraiser if no market value is known, and the tax is due within 15 days after the change. The company must appoint a legal representative who meets LISR art. 174, keeps the supporting documents and is jointly and severally liable for the company's taxes. SAT's notice for a change of residence must be filed no later than 15 days before the change and no more than two months in advance.
Cost to do it: The exit tax is 30 percent on the deemed gain (LISR art. 9); appraisal and representative costs are private.
Example: A Mexican holding company with assets of tax cost MXN 200,000,000 and market value MXN 260,000,000 moves its residence abroad. The deemed gain of MXN 60,000,000 bears tax of MXN 18,000,000, due within 15 days. / Deemed gain of about USD 3,214,779 and tax of about USD 964,434.Ley del Impuesto sobre la Renta (LISR), DOF 11 December 2013 (Chamber of Deputies consolidated text, last reform DOF 1 April 2024), Art. 12, second to fourth paragraphs; Annex 2 sheet 128/CFF, 2013-12-11 official text · verified 2026-10-26
5. To have SAT register the start of liquidation (notice 128/CFF), the company must already have filed the annual return for the year that ended early, have a positive compliance opinion, e.firma for the company and the liquidator, an active tax mailbox and a locatable address where the books are kept. SAT may send a verification order to that address and resolves within 30 days.
Cost to do it: Free.
Example: If the short year return is filed late, SAT will not record the liquidation status until it is filed. / No government fee; USD 0.Annex 2 to the Resolución Miscelánea Fiscal para 2026 (procedure sheets), SAT compilation including the First Amendment, DOF 17 July 2026, Procedure sheet 128/CFF, 2026-07-17 official text · verified 2026-10-26
FilingPeriod coveredDue
Short year return1 Jan to 30 Apr 2026By 30 Jul 2026
Notice 128/CFFStart of liquidationWithin the month after the short year return
Monthly provisional paymentsEach month from May 202617th of the following month
Annual liquidation return1 May to 31 Dec 202617 Jan 2027
Final liquidation return1 May 2026 to 31 Mar 2027By 30 Apr 2027
Notice 129/CFFCancellationWithin the month after liquidation ends

Tax filings in a liquidation starting 1 May 2026 and ending 31 March 2027 (CFF art. 11; LISR arts. 9 and 12)

Worked example

  • A subsidiary in liquidation sells its plant in October 2026 for MXN 40,000,000 with a remaining tax basis of MXN 25,000,000. The MXN 15,000,000 gain enters the liquidation year result; at 30 percent the tax is MXN 4,500,000 (about USD 241,108), paid through the monthly payments, the January 2027 return and the final return.
  • Losses carried into the liquidation year and deductible liquidation costs reduce that result; the final return trues up all payments.

Step by step

  1. 1. Close the books on the day liquidation starts and prepare the short year return.
  2. 2. File the short year return within three months, then notice 128/CFF.
  3. 3. Diary the 17th of each month for provisional payments and 17 January for each year.
  4. 4. Track gains on asset sales and deductible liquidation costs month by month.
  5. 5. File the final liquidation return within the month after the last asset is realized, then notice 129/CFF.

Common traps

  • Assuming one final return is enough: each calendar year of a long liquidation needs its own return by 17 January (LISR art. 12).
  • Forgetting foreign branches: they are excluded from monthly payments but included in the final return (LISR art. 12).
  • Redomiciling a Mexican company abroad without planning: it is a deemed liquidation at market value with tax due in 15 days (LISR art. 12).
  • Filing notice 128/CFF before the short year return: SAT requires the return first (Annex 2, 128/CFF).

Sources

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