Generalized and customized reportable schemes designed, marketed, organized, implemented, or administered by a tax advisor resident in Mexico or a resident abroad with a permanent establishment must be disclosed. A reportable scheme must be disclosed regardless of the taxpayer's tax residency, provided that the taxpayer obtains a tax benefit in Mexico.

The mandatory disclosure provisions will not apply to tax advisors or taxpayers with respect to reportable schemes, provided that they are customized and the aggregate amount of the tax benefit obtained or expected to be obtained in Mexico does not exceed 100 million pesos.