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Bitcoin tax framework for corporations in Mexico
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Bitcoin tax framework for corporations in Mexico

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By Aureo 14 January 202615 min read

This is educational information, not tax, legal, or accounting advice. Treatment may vary depending on your business model (treasury, trading, payments, mining, custody, etc.). Updated as of January 2026. Validate your specific case with an accountant or tax advisor in Mexico.

How much tax does a company pay on bitcoin in Mexico?

Companies in Mexico (legal entities/corporations) can legally buy, hold, and sell bitcoin. The critical point to understand is that Mexico does not have a specific "crypto tax regime" for corporations: the treatment derives from general rules (income tax, NIF accounting standards, and documentation), applied with conservative criteria and robust evidence.

This document explains the complete framework for (1) income tax, (2) accounting records under NIF, and (3) controls and documentation that reduce compliance risks.

TL;DR

What you need to know in 60 seconds:

  • Tax (ISR): When a company disposes of bitcoin (sells for MXN, exchanges for another asset, or uses it to pay), it generates a taxable gain or loss that is taxed at 30% as part of the fiscal year result.

  • Accounting (NIF C-22): Bitcoin is classified as a short-term digital asset (it is not cash, intangible, or a financial instrument). It is valued at fair value when an active market exists with Level 1 or 2 inputs; otherwise, fair value = 0.

  • The real risk: It's not the tax rate, but the lack of traceability. Without documented evidence of ownership, valuation, TXIDs, and formal policies, deductions can be rejected and audit risks emerge.

  • VAT: Generally considered outside the scope for asset purchase/sale, but intermediation services (exchange commissions) do trigger 16% VAT.

  • Minimum documentation: Valuation policy, transaction log, on-chain evidence, exchange statements, and formal accounting policies.

1) Regulatory framework: where is all this written?

1.1 Legal and accounting classification (NIF C-22)

NIF C-22 "Cryptocurrencies", issued by CINIF and effective since January 1, 2021, establishes the rules for recognition, measurement, presentation, and disclosure of cryptocurrencies in Mexican financial statements.

Bitcoin is classified as:

  • Short-term digital asset (no physical substance, identifiable, provides future economic benefits)
  • NOT: cash, cash equivalent, financial instrument, or investment property

Scope of NIF C-22:

  • Entities that hold cryptocurrencies
  • Mining activities
  • Custody services
  • Financial instruments denominated in cryptocurrencies

1.2 Tax treatment (LISR)

For Income Tax purposes, bitcoin transactions are governed under the disposal of assets regime in Title II (Corporations). There is no specific cryptocurrency tax legislation in 2026, so general rules are applied with conservative criteria.

Key regulatory sources:

  • Income Tax Law (LISR) - Title II Articles
  • NIF C-22 (Cryptocurrencies)
  • NIF B-17 (Fair value determination)
  • Federal Tax Code (document retention)

2) Accounting under NIF: how to record bitcoin in your financial statements

2.1 Initial recognition

When do you recognize bitcoin as an asset?

When it meets the definition of an asset (NIF A-1):

  • It is a controlled resource by the company
  • Generates future economic benefits
  • Derives from past events (the acquisition)

Required evidence of control:

  • Possession of access keys to platforms that allow transactions
  • Platform confirmation that the entity is the owner
  • Possession of private key (in case of self-custody)

Acquisition cost includes:

  • Price paid for the asset
  • Directly attributable costs: exchange commissions, transfer costs, identifiable spreads

Important note: If the cost differs from fair value at acquisition date, the difference is recognized as gain or loss in Net Profit or Loss (UPN).

2.2 Subsequent measurement: fair value and the "zero value" rule

Valuation methodology (NIF C-22 + NIF B-17):

Cryptocurrencies are valued at fair value at each reporting date, following the NIF B-17 hierarchy:

  • Level 1: Quoted prices in active markets for identical assets
  • Level 2: Observable inputs other than Level 1 quoted prices
  • Level 3: Unobservable inputs (generally not acceptable for crypto)

CRITICAL RULE: If fair value cannot be determined using Level 1 or Level 2 inputs, fair value = 0 is assumed.

What is an "active market"?

A market with:

  • Frequent and regular transactions
  • Sufficient volume to establish reliable prices
  • Verifiable crypto-to-fiat quotes
  • Regulated or supervised source

Your valuation policy must specify:

  • Source exchange(s) used (e.g., Bitso, Binance)
  • Hierarchy if discrepancies exist between sources
  • Cut-off time (e.g., 11:59 PM Mexico City time)
  • MXN/USD exchange rate and its source (e.g., Banxico)
  • Documentation method (screenshots, API logs, statements)

2.3 Value fluctuations and impairment

While holding the asset:

  • Fluctuation adjustments are recognized in Comprehensive Financing Result (RIF)
  • If market value falls below book value: impairment loss in income statement
  • Impairment reversals are permitted up to original book value (no revaluation above cost)

No amortization: Bitcoin is not a finite-life intangible asset.

2.4 Presentation in financial statements

Statement of financial position:

  • Specific line item in short-term assets: "Cryptocurrencies" or "Digital Assets"

Income statement:

  • Valuation effects in Comprehensive Financing Result (RIF)
  • Gains/losses from disposal in the transaction period

Statement of cash flows:

  • Purchases and sales classified as operating activities

Required disclosures (notes):

  • Name of cryptocurrency type
  • Intended use (treasury, trading, payments)
  • Number of units at closing
  • Unit fair value
  • Total carrying amount
  • Effects on RIF from valuation
  • For third-party custody: quantity and fair value held

3) Tax treatment (ISR): when and how much is paid

3.1 Applicable rate

30% on the fiscal year result (standard corporate rate for legal entities).

Gains from bitcoin disposal are considered "other taxable income" under Article 18 of LISR.

3.2 Taxable event: "disposal"

Considered disposal:

  • Sale for fiat currency (MXN, USD, etc.)
  • Exchange for other cryptocurrencies
  • Exchange for other assets
  • Payment in kind for obligations
  • Payroll or service payments
  • Settlement of liabilities (using bitcoin to pay supplier debts)

3.3 Determination of taxable income

Formula:

Taxable Income = Sale Price - Tax Basis

Where:

  • Sale price: Market value in Mexican pesos at the time of transaction
  • Tax basis: Original acquisition cost + acquisition expenses (commissions, transfers, identifiable spreads)

Costing method: Must be consistent (specific identification, weighted average, or FIFO). Document your chosen method and apply it consistently.

3.4 Timing of income recognition

Income is recognized at the moment the disposal occurs, not when price fluctuates.

Important: Value fluctuations while holding bitcoin DO NOT generate income tax. You only pay tax when you dispose of it.

3.5 Provisional payments

Corporations must make monthly provisional income tax payments. Gains or losses from bitcoin disposal during the period affect:

  • Accumulated nominal income
  • Fiscal year result
  • Applicable profit coefficient (based on previous year)

4) Common operational scenarios

4.1 Bitcoin as treasury reserve

Case: Your company buys bitcoin as a hedging strategy against peso devaluation.

Treatment:

MomentAccounting TreatmentTax Treatment
PurchaseRecognize digital asset at acquisition costNo tax effect
Monthly/annual closingRevalue at fair value → RIF adjustmentNo tax effect (no disposal)
SaleDerecognize asset + recognize gain/lossTaxable gain at 30%

Advantages:

  • Treasury diversification
  • Potential protection against devaluation
  • Exposure to asset with long-term appreciation history

Risks:

  • Volatility impacts financial statements and may affect banking covenants
  • Additional accounting and tax complexity
  • Custody and operational security risk

4.2 Receiving bitcoin as payment for goods/services

Case: You sell a product/service and the customer pays in bitcoin.

Required steps:

  1. Determine value in MXN at the moment of collection (using documented valuation policy)
  2. Issue CFDI (tax invoice) in Mexican pesos for the equivalent amount
  3. Record accounting entries:
    • Operating income from the sale (applicable regime)
    • Bitcoin receipt as digital asset
  4. Save evidence: Quote, exchange rate, TXID, confirmations

Two taxable moments:

  • Moment 1: Operating income from the goods/services sale
  • Moment 2: Subsequent gain or loss if you sell that bitcoin at a different price

4.3 Paying suppliers with bitcoin

Case: You use bitcoin from your treasury to pay a supplier.

Treatment:

  1. Considered bitcoin disposal → generates taxable gain or loss
  2. Supplier must issue CFDI in Mexican pesos
  3. Income tax withholding obligations may arise if supplier is an individual (case-by-case evaluation)

Required documentation:

  • Value in MXN at payment time (valuation policy)
  • TXID and transfer evidence
  • Supplier's CFDI
  • Taxable gain/loss calculation

4.4 Complete numerical example

Assumption: Your company (general regime) decides to hold bitcoin in treasury.

Fiscal year operations:

DateOperationDetailMXN Amount
Mar 15, 2025Purchase1 BTC + $2,000 commission$502,000
Mar 31, 2025Monthly closingMarket valuation$600,000
Jun 30, 2025Quarterly closingMarket valuation$550,000
Sep 15, 2025Sale1 BTC - $3,000 commission$697,000

Accounting entries:

Mar 15, 2025 (Purchase):

Digital Assets           $502,000
    Banks                           $502,000
  • Tax basis = $502,000

Mar 31, 2025 (Revaluation):

Digital Assets           $98,000
    RIF (unrealized gain)           $98,000
  • Book value = $600,000
  • No tax effect (no disposal)

Jun 30, 2025 (Revaluation):

RIF (unrealized loss)    $50,000
    Digital Assets                  $50,000
  • Book value = $550,000
  • No tax effect (no disposal)

Sep 15, 2025 (Sale):

Banks                    $697,000
    Digital Assets                  $550,000
    Gain on sale                    $147,000

Tax calculation:

  • Sale price = $697,000
  • Tax basis = $502,000
  • Taxable gain = $195,000
  • Income tax payable = $58,500 (30%)

Note: Accounting gain ($147,000) differs from tax gain ($195,000) because you had already recognized fluctuations in RIF for accounting purposes. For tax purposes, only the difference between sale price and original cost matters.

5) VAT treatment

Current situation (January 2026):

There is no universal specific rule for VAT on bitcoin transactions. Treatment depends on the legal and economic characterization of each transaction.

Common criterion in practice:

  • Asset purchase/sale: Generally treated as outside the scope/not subject to VAT
  • Intermediation services: Exchange commissions and fees DO trigger 16% VAT

Creditable VAT:
Commissions paid to exchanges generate creditable VAT for the company (if you meet general crediting requirements).

Critical recommendation:

  • Document the criterion adopted with your tax advisor (memo or internal policy)
  • Apply it consistently across all transactions
  • Review regulatory updates periodically

6) Documentation obligations: the definitive checklist

6.1 What does your accountant need to close the year properly?

Required tax documents:

  1. Formal valuation policy (approved document specifying):

    • Price sources (accepted exchanges)
    • Hierarchy for discrepancies
    • Cut-off time
    • MXN exchange rate source
    • Recording methodology
  2. Transaction log (Excel or accounting system):

    • Date and time
    • Transaction type (buy/sell/exchange)
    • BTC quantity
    • Unit price in MXN
    • Total amount
    • Counterparty (exchange/person)
    • Wallet or exchange used
    • Folio/reference
  3. Market evidence for each valuation:

    • Timestamped screenshots
    • Exchange statements
    • API logs (if applicable)
    • Exchange rate documentation used
  4. Exchange receipts:

    • Buy/sell confirmations
    • Monthly statements
    • Transaction history
    • Commission receipts
  5. On-chain traceability:

    • TXID for each transaction
    • Source and destination address
    • Confirmation date and time
    • Link to corresponding accounting entry
  6. Evidence of control/custody:

    • Contracts with custodians (if applicable)
    • Own wallet documentation
    • Access policies and segregation of duties
    • Backups and recovery procedures
  7. Formal accounting policies:

    • Costing method (FIFO/average/specific)
    • Recognition criteria
    • Commission treatment
    • Impairment policies

6.2 Digital assets subsidiary ledger

Recommended fields:

DateTXIDOperationBTC QuantityUnit Price MXNTotal MXNCumulative Tax BasisBTC BalanceExchange/WalletNotes

6.3 Information retention

Minimum period: 5 years from tax return filing (Federal Tax Code).

Extended period: Some documents must be retained longer if they have extended effects (capital, tax loss carryforwards, etc.).

7) Loss deductibility

Are bitcoin losses deductible?

Yes, subject to requirements:

Conditions for deduction:

  1. Complete documentation: Evidence of the transaction (confirmations, TXIDs, statements)
  2. Proper accounting record: Reflected in accounting per NIF
  3. Necessary character: Demonstrate it was performed in the normal course of business
  4. Clear traceability: Ability to link acquisition cost with sale price

The challenge in crypto: It's not the concept (losses are deductible under general principles), but robust documentary proof.

Common errors that reject deductions:

  • No evidence of acquisition cost
  • Inconsistent or unsupported valuations
  • Lack of TXIDs or on-chain traceability
  • Related-party transactions without market price
  • Incomplete accounting record

8) Bitcoin in corporate treasury: recommended policy

8.1 Elements of a solid internal policy

Formal document (approved by Board/Management) including:

1. Objective and scope:

  • Purpose (treasury, diversification, payments)
  • Maximum limits (% of liquid assets/cash)
  • Investment horizon

2. Governance:

  • Decision makers (who authorizes purchases/sales)
  • Execution responsible (who operates)
  • Reconciliation responsible (who verifies)
  • Segregation of duties (no one has complete access alone)

3. Custody:

  • Modality (self-custody vs third-party custodian)
  • Backup procedures
  • Access controls (multisig, 2FA)
  • Continuity plan for loss of access

4. Operating criteria:

  • Authorized exchanges or custodians
  • Limits per transaction
  • Conditions for buy/sell
  • Required approvals by amount

5. Valuation and recording:

  • Valuation policy (see section 2.2)
  • Reconciliation frequency (daily/weekly)
  • Accounting record responsible
  • Monthly/annual closing

6. Risk management:

  • Exposure limits
  • Procedures for extreme volatility
  • Incident plan (hack, loss, error)
  • Insurance or hedges (if available)

8.2 Minimum operational controls

Secure custody:

  • Multisignature wallets (requires multiple signatures to transact)
  • Hardware wallets in secure locations (safes, vaults)
  • Encrypted backups in multiple locations
  • Seed phrases divided among custodians (no single person with complete access)

Regular reconciliation:

  • Daily: Verify balances in exchanges/wallets vs accounting
  • Weekly: Review transaction log vs statements
  • Monthly: Market valuation and RIF adjustment recording
  • Annual: Complete on-chain traceability audit

Segregation of duties:

  • Person A: Authorizes transactions
  • Person B: Executes transactions
  • Person C: Reconciles and records accounting
  • No person should have complete access to the entire process

9) Common compliance risks and how to avoid them

9.1 Errors that generate audit observations

RiskCauseConsequencePrevention
Deduction rejectionLack of tax basis evidenceNon-deductible lossesSave purchase confirmations, TXIDs, statements
Challenged valuationNot using Level 1/2 sourcesTax adjustmentsFormal policy with verifiable sources
Lost traceabilityNot linking TXID with entryCannot support transactionsComplete ledger on-chain ↔ accounting
Misapplied VATInconsistent criteriaTax contingenciesDocument criterion with advisor and apply consistently
Control not demonstratedNot proving key possessionAsset not recognizedCustody evidence (wallets, contracts, confirmations)

9.2 Red flags that trigger reviews

Authorities may pay attention if:

  • Recurring losses without clear documented strategy
  • Related-party transactions without market price
  • Inconsistent valuations between periods
  • Lack of supporting documentation
  • Intensive use without formal approved policy
  • Material differences between accounting and tax without reconciliation

10) Frequently asked questions

Do I pay taxes if I only buy and hold bitcoin?
No. Income tax is triggered when you dispose of it (sell, exchange, or use to pay). Holding bitcoin generates accounting fluctuations in RIF but does not cause income tax until disposal.

Can I deduct exchange commissions?
Yes. Commissions are added to the asset's acquisition cost, reducing the taxable gain when you dispose of it.

What happens if I cannot determine fair value?
If there is no active market with Level 1 or 2 data (NIF B-17), you must assume fair value = 0, which impacts your accounting presentation and may generate observations.

Is a formal policy mandatory?
It's not explicitly in law, but it's highly recommended. In audits or tax reviews, the absence of a formal policy significantly increases the risk of observations and deduction rejection.

What costing method should I use (FIFO, average, specific)?
You can choose, but it must be consistent and documented. FIFO (first in, first out) is common. Specific works if you can trace each unit (e.g., separate wallets).

Does bitcoin generate PTU (Employee Profit Sharing)?
Disposal gains are integrated into the fiscal result, which is the basis for PTU. Consult with your accountant on specific treatment in your structure.

Can I pay payroll in bitcoin?
Technically yes, but it's complex: you must convert to MXN for CFDI and withholding purposes, and bitcoin delivery is considered disposal (generates taxable gain/loss for the company). Not a common practice in Mexico in 2026.

11) Conclusion and next steps

For corporations in Mexico, bitcoin is treated under general ISR and NIF rules, without a specific regime. Operational success depends on:

Three fundamental pillars:

  1. Accounting aligned with NIF C-22 (recognition, valuation, presentation)
  2. ISR tax compliance (correct determination of gain/loss, provisional payments)
  3. Robust documentation (evidence of control, traceability, formal policies)

The framework is clear, but requires operational discipline.

Implementation checklist (recommended order):

Week 1-2: Fundamentals

  • [ ] Define objective (treasury vs trading vs payments)
  • [ ] Approve formal internal policy
  • [ ] Select exchange(s) or custodian
  • [ ] Define exposure limits

Week 3-4: Operational

  • [ ] Implement secure custody (wallets, segregation)
  • [ ] Create transaction log (template)
  • [ ] Define valuation policy (sources, time, FX)
  • [ ] Establish reconciliation process

Week 5-6: Accounting/Tax

  • [ ] Align NIF C-22 criteria with accountant
  • [ ] Document costing method
  • [ ] Prepare monthly evidence format
  • [ ] Validate VAT criterion with advisor

Ongoing: Maintenance

  • [ ] Weekly reconciliation (balances vs accounting)
  • [ ] Monthly valuation (accounting close)
  • [ ] Quarterly backup (evidence, TXIDs)
  • [ ] Annual review (policy, controls, compliance)

Technical glossary

Digital asset: Electronically controlled resource, without physical substance, that generates future economic benefits.

Tax basis: Original acquisition amount plus directly attributable expenses (commissions, transfers).

Disposal: Sale, exchange, donation, payment in kind, or any act that transfers ownership of the asset.

Active market: Market where transactions are frequent, with sufficient volume to establish reliable prices.

NIF B-17: Financial Information Standard that establishes the hierarchy for determining fair value (Level 1, 2, 3).

NIF C-22: Financial Information Standard specific for recognition, valuation, and presentation of cryptocurrencies.

RIF (Comprehensive Financing Result): Section of the income statement where valuation fluctuations of financial assets are recognized.

TXID (Transaction ID): Unique identifier of a blockchain transaction, on-chain evidence of transfer.

Fair value: Price that would be received to sell an asset in an orderly transaction between market participants at the measurement date.