Countries › Mexico › Guide › 10. Capital markets and finance › Investment funds, FIBRAs and private equity trusts in Mexico: fund types and setup, CNBV fees, the FIBRA real estate trust tax regime and venture capital trusts (FICAP)

Investment funds, FIBRAs and private equity trusts in Mexico: fund types and setup, CNBV fees, the FIBRA real estate trust tax regime and venture capital trusts (FICAP)

Argentina. For full detail on Argentina, go to The Argentine Thread.

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

Mexican investment funds are companies of four types (equity, debt, private capital and hedge funds) created before the CNBV by a single founder, the fund operator, with a CNBV approved prospectus; in 2026 the operator license costs MXN 502,270 and each fund MXN 107,428 in CNBV duties. A FIBRA is a Mexican trust that rents out real estate, places its certificates publicly in Mexico, keeps at least 70 percent in real estate and distributes at least 95 percent of its tax result by 15 March; it makes no provisional tax payments and holders bear 30 percent withholding, final for foreign residents. A FICAP venture capital trust gets pass through treatment if at least 80 percent is invested in unlisted Mexican companies held at least two years and 80 percent of income is distributed within two months of year end.

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. Legal conversions in Mexico use the Banxico FIX, which differs slightly. Conversions are for orientation only.

Key facts

Investment fund types	Equity, debt, private capital, hedge LFI art. 6, as of 2026-10-26 · in force
CNBV duties for a full fund operator license (2026)	502270 MXNLFD art. 29, I and II, as of 2026-10-26 · in force
CNBV duties per fund (2026)	107428 MXNLFD art. 29, VII and XXI, as of 2026-10-26 · in force
Minimum real estate share of FIBRA assets	70 %LISR art. 187, III, as of 2026-10-26 · in force
Minimum FIBRA distribution of prior year tax result	95 %LISR art. 187, VI, as of 2026-10-26 · in force
Minimum FIBRA property holding period for the regime	4 yearsLISR art. 187, IV, as of 2026-10-26 · in force
Withholding on FIBRA distributions to foreign residents without PE	30 % (final tax)LISR arts. 9 and 188, IV and V, as of 2026-10-26 · in force
Minimum share of FICAP assets in unlisted Mexican companies	80 %LISR art. 192, III, as of 2026-10-26 · in force
Argentina and Mexico double tax agreement in force	2017-08-23 dateArgentina Ley 27.334, as of 2026-10-26 · in force

The rule

1. Fund types and how a fund is created. Investment funds must adopt one of four types according to their investment regime: equity (renta variable), debt instruments, private capital (de capitales) or hedge (de cobertura), and are supervised and sanctioned by the CNBV; pension investment companies (SIEFORES) are under CONSAR instead. A fund is created by a single founding partner, which must be a fund operator, appearing before the CNBV after authorization, without a notary or commercial registry filing; registration in the RNV has the same effect as commercial registry filing and the CNBV charges no duty for registering the fund itself. Prospectuses and their changes need prior CNBV authorization and must set out sale policy and holding limits, trading and settlement, investment and liquidity policies, and risk warnings.
Cost to do it: Each fund pays 2026 CNBV duties of MXN 36,734 for the study and MXN 70,694 for authorization, MXN 107,428 in total (USD 5,756).
Example: An operator launching three funds (equity, debt and private capital) pays MXN 322,284 in CNBV fund duties. / About USD 17,268.Ley de Fondos de Inversión (LFI), DOF 4 June 2001, last reform DOF 14 November 2025 (Chamber of Deputies consolidated text); art. 6 section IV reformed DOF 28 December 2023, Arts. 6, 8 Bis and 9, 2023-12-28 official text · verified 2026-10-26

2. Fund operator license. Fund operators, distributors and valuers need CNBV authorization; in 2026 the study costs MXN 44,510 and the authorization MXN 457,760, while an operator limited to private capital or limited purpose funds pays MXN 400,737 for its authorization.
Cost to do it: Full operator: MXN 502,270 (USD 26,911). Private capital only operator: MXN 445,247 (USD 23,856).
Example: A foreign asset manager setting up a Mexican operator and its first two funds pays MXN 717,126 in CNBV duties. / About USD 38,423.Ley Federal de Derechos (LFD), last reform DOF 7 November 2025; 2026 amounts in Anexo 4 de la Resolución Miscelánea Fiscal para 2026, DOF 28 December 2025, LFD art. 29, sections I to III, VII and XXI, 2025-12-28 official text · verified 2026-10-26

3. FIBRA requirements. A trust gets the FIBRA tax regime if it is set up under Mexican law with a Mexican bank or casa de bolsa as trustee; its main purpose is acquiring or building real estate for lease, acquiring rights to rental income, or lending for those purposes secured by mortgages on the leased property; at least 70 percent of its assets are in such real estate, rights or loans and the rest in federal government securities registered in the RNV or debt fund shares; properties are not sold within four years of completion or acquisition; its participation certificates are placed in Mexico among the general investing public; it distributes at least 95 percent of the prior year's tax result at least once a year by 15 March; variable or percentage rents (other than a fixed percentage of tenant sales) do not exceed 5 percent of annual rental income; it is registered with the SAT; and the trustee files contributor and property information by 15 February each year.
Cost to do it: Listing and trustee costs are market priced.
Example: A FIBRA with a 2025 tax result of MXN 100,000,000 must distribute at least MXN 95,000,000 by 15 March 2026. / MXN 95,000,000 is about USD 5,090,067.Ley del Impuesto sobre la Renta (LISR), DOF 11 December 2013, last reform DOF 1 April 2024 (Chamber of Deputies consolidated text); art. 187 section V reformed DOF 9 December 2019, Art. 187, 2013-12-11 official text · verified 2026-10-26

4. FIBRA taxation. The trustee computes the trust's tax result under the corporate rules, divides it by the certificates outstanding and makes no provisional tax payments. Distributions of the tax result bear withholding at the 30 percent corporate rate unless the holder is exempt; for publicly placed certificates the custodian intermediary withholds. Mexican residents and foreign residents with a permanent establishment include the distributions in income and credit the withholding; for other foreign residents the withholding is a final tax. Mexican pension funds may apply their exemption. If a property is sold before four years, the trustee pays 30 percent on the gain within 15 days on behalf of holders.
Cost to do it: 30 percent withholding on distributed tax result.
Example: A foreign fund without a Mexican permanent establishment that receives MXN 1,000,000 of FIBRA tax result distributions bears MXN 300,000 withholding as its final Mexican tax, before any treaty analysis. / MXN 300,000 is about USD 16,074.Ley del Impuesto sobre la Renta (LISR), DOF 11 December 2013, last reform DOF 1 April 2024 (Chamber of Deputies consolidated text); art. 188 section IV first paragraph reformed DOF 12 November 2021, Arts. 9 and 188, 2013-12-11 official text · verified 2026-10-26

5. Venture capital trusts (FICAP). Investors in shares of unlisted Mexican resident companies, and in loans to them, get the art. 193 treatment through a trust with a Mexican bank or casa de bolsa as trustee whose main purpose is to invest in and finance those companies and sit on their boards, with at least 80 percent of assets invested in them (the rest in federal government securities or debt fund shares), shares held at least two years, and at least 80 percent of the income received in the year distributed within two months after year end, plus SAT rules. Investors are taxed on the income the trustee passes through under the regime that applies to each of them, with separate accounts kept by income type.
Cost to do it: Trustee and fund management costs are market priced.
Example: A FICAP that receives MXN 20,000,000 of dividends and gains in 2026 must distribute at least MXN 16,000,000 by the end of February 2027. / MXN 16,000,000 is about USD 857,275.Ley del Impuesto sobre la Renta (LISR), DOF 11 December 2013, last reform DOF 1 April 2024 (Chamber of Deputies consolidated text), Arts. 192 and 193, 2013-12-11 official text · verified 2026-10-26

Vehicle	Form	Key test	Tax point	Rule
Investment fund	Company created by a fund operator before the CNBV	CNBV approved prospectus	Fund level rules not covered here	LFI arts. 6, 8 Bis and 9
FIBRA	Trust with Mexican bank or casa de bolsa trustee, public certificates	70 percent real estate, 95 percent payout by 15 March, 4 year hold	No provisional payments; 30 percent withholding on distributions	LISR arts. 187 and 188
FICAP	Trust with Mexican bank or casa de bolsa trustee	80 percent in unlisted Mexican companies, 2 year hold, 80 percent payout	Investors taxed on passed through income	LISR arts. 192 and 193

Mexican pooled vehicles compared, verified 26 October 2026 against the LFI, LISR and LFD.

Worked example

A foreign pension fund without a Mexican permanent establishment buys listed FIBRA certificates.
The FIBRA's 2025 tax result attributable to the fund is MXN 5,000,000 (about USD 267,898); the FIBRA must distribute it by 15 March 2026 (LISR art. 187, VI).
The custodian withholds 30 percent, MXN 1,500,000 (about USD 80,369), as a final Mexican tax, unless an exemption or treaty applies (LISR art. 188, IV and V).
The fund nets MXN 3,500,000 (about USD 187,529) before any treaty relief or home country credit.

Step by step

1. Choose the vehicle: an investment fund for pooled portfolios, a FIBRA for rental real estate with public investors, a FICAP for venture and private equity in unlisted Mexican companies.
2. For funds, license or engage a fund operator and file each fund's prospectus with the CNBV (LFI arts. 8 Bis and 9; LFD art. 29).
3. For a FIBRA, appoint a Mexican bank or casa de bolsa trustee, register with the SAT and plan the public placement in Mexico (LISR art. 187).
4. Calendar the 15 February information filing and the 15 March 95 percent distribution each year (LISR art. 187, VI and IX).
5. For a FICAP, track the two year holding period and the 80 percent distribution within two months of year end (LISR art. 192).
6. Foreign investors from treaty countries, including Argentina, whose agreement with Mexico has been in force since 23 August 2017, should check whether the treaty changes the withholding result.

Common traps

Selling a FIBRA property before four years costs the regime for that property and triggers 30 percent tax on the gain within 15 days (LISR arts. 187, IV, and 188, VII).
Missing the 95 percent distribution by 15 March breaks a FIBRA requirement (LISR art. 187, VI).
FIBRA certificates must be placed publicly in Mexico; a private real estate trust does not qualify (LISR art. 187, V).
Variable rents above 5 percent of annual rental income break the FIBRA test, except rents set as a fixed percentage of tenant sales (LISR art. 187, VII).

Sources

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