Within the regulations contained in Article 27 of the Federal Tax Code and administrative procedure rules issued by the Tax Administration Service (Servicio de Administraci\u00f3n Tributaria – SAT), legal entities must maintain updated information regarding partners, shareholders, and associates who form part of the organizational structure in accordance with the bylaws or the legislation under which they are incorporated, as well as legal representatives.<\/p>\n
Compliance with this obligation<\/strong><\/span><\/p>\n Legal entities, through the SAT website, must submit a notice reporting the name and Tax ID key of their partners, shareholders, associates, and other persons, whatever title they may be designated by pursuant to their bylaws, whenever a modification or incorporation occurs. This notice must include:<\/p>\n The notice must be submitted within 30 business days following the date on which the modification or incorporation of partners, shareholders, or legal representatives occurs. The procedure must be accompanied by the notarized document certifying the corresponding change; for further reference, it is recommended to review procedure file 38\/Tax Code of Annex 2 of the Miscellaneous Tax Resolution for 2026. We share the link where you can consult this procedure https:\/\/www.sat.gob.mx\/minisitio\/NormatividadRMFyRGCE\/documentos2026\/rmf\/anexos\/Primera-Modificacion-Anexo-2-DOF-17072026.pdf<\/a><\/strong><\/span><\/p>\n The system application establishes the obligation to indicate the number of shares or the nominal value of the social parts, so that the SAT’s own system automatically calculates the percentage of participation of each partner or shareholder.<\/p>\n In accordance with Miscellaneous Tax Rule 2.4.14 for 2026, it is established that within this same application, legal entities may incorporate or update the information of their legal representatives, thereby complying with the provisions of Article 19 of the Federal Tax Code regarding registration in the registry of legal representatives.<\/p>\n Concept of effective control<\/span><\/strong><\/p>\n One of the concepts that usually draws attention in this notice of partners and shareholders is the so-called “Effective Control”. The Federal Fiscal Code establishes that effective control shall be understood as the capacity of a person or group of persons to carry out any of the following acts:<\/p>\n Additional comments<\/span><\/strong><\/p>\n It is important to have all legal documentation properly notarized, supporting the composition of the capital stock and the participation of partners or shareholders, shares or social parts, and the granting or revocation of powers of attorney.<\/p>\n In the case of foreign partners or shareholders: the generic Tax ID is EXT990101NI1 (for legal entities) or EXTF900101NI1 (for individual persons) must be used when they do not have a Tax ID registered with the SAT.<\/p>\n It is important to mention that the SAT does not allow the completion of the procedure if the tax status of the partner or shareholder is not in “Active” status. It is recommended to verify the status of each of them in advance to avoid delays.<\/p>\n The notice remains valid until a new modification or incorporation is submitted; there is no obligation to renew it periodically if there are no changes in the shareholding structure.<\/p>\n If it is the first time that a request is being submitted in the application named Socios y Accionistas (Partners and Shareholders), the notice for the updating of partners and shareholders must be submitted first and, following its approval, the notice for the updating of legal representatives.<\/p>\n To submit the notice to the SAT, the following documentation and\/or information is required:<\/p>\n Sanctions pursuant to Articles 79 and 80 of the Federal Tax Code for failing to submit these notices can range from $5,400 to $10,780 Mexican pesos, in addition to a possible restriction of digital seal certificates in accordance with Article 17-H Bis of the same Federal Tax Code.<\/p>\n At Nu\u00f1ez Rosas y Asociados S.C., we are at your disposal to review with you or with your legal area and\/or legal advisors any questions and\/or comments in this regard. It is essential that legal entities report any changes regarding their partners, shareholders, and effective control to the SAT on time, as well as changes in the entity’s legal representation.<\/p>\n Nu\u00f1ez Rosas y Asociados S.C. is a member of Nexia, a leading, global network of independent accounting and consulting firms, providing a comprehensive portfolio of audit, accountancy, tax and advisory services. Nexia works with its member firms leveraging strength across the network and enabling the delivery of global solutions by member firms to their clients https:\/\/nexia.com\/disclaimer\/<\/a><\/span><\/strong><\/p>\n\n
\n
\n