When Mexico's name appeared on the list of host cities for the FIFA World Cup 2026, authorities announced millions in economic revenue, stadium modernization, and tourism attraction. However, little was explained about the other side of the equation: the fiscal, administrative, and legal costs Mexico assumed to be able to host.
Along with the World Cup came a tax, customs, and administrative exception regime built specifically for FIFA and its affiliated entities. This is a parallel system where the ordinary rules that apply to all Mexican taxpayers simply do not apply. This analysis explains what these exemptions consist of, what instruments support them, and what constitutional principles they strain.
The International Federation of Association Football (FIFA) is not a public international body. It is a private law association based in Switzerland that operates with a business logic, generating multi-billion dollar revenues (over $7.5 billion in the 2018-2022 cycle). Given this economic capacity, it is legally relevant to ask how a state justifies exempting it from tax obligations.
The answer lies in FIFA's model: the requirement for Government Guarantees. This mechanism makes granting the hosting rights conditional on the host state legally committing to guarantee extraordinary operational and fiscal conditions.
In 2018, the Mexican State signed this Guarantee, assuming commitments that included:
In the realm of international law, state commitments transcend changes in administration. Therefore, the incumbent government had to give normative form to these prior agreements through working groups that resulted in three central legal instruments.
To understand the scope of this parallel scheme, it is useful to break down the three regulatory instruments approved for the organization of the 2026 World Cup:
| Legal Instrument | Impact Area | Main Benefit for FIFA and Affiliates |
|---|---|---|
| Interinstitutional Agreement | Non-tariff regulations | Simplified accreditation of regulations (sanitary, environmental) through sworn statements. |
| Rule 4.2.21 (General Foreign Trade Rules) issued by the SAT (in its powers granted by Article 33, section I, subsection g) of the Fiscal Code of the Federation) and Form A10 | Customs and Foreign Trade | Simplified temporary import and exemption from payment of the Customs Processing Fee (DTA). |
| Twenty-fifth Transitory Provision (Law of Income of the Federation for the Fiscal Year 2026) | Fiscal and Tax | Exemption from payment, withholding, and transfer of federal contributions such as Income Tax and VAT. |
Under ordinary conditions, bringing goods into Mexico requires compliance with health, safety, and environmental controls (COFEPRIS, SENASICA, etc.). This Agreement creates a regime where equipment, infrastructure, and goods for the World Cup will enter through simplified mechanisms, bypassing the ordinary verifications that any national company must meet for identical goods.
Temporary imports normally require customs declarations, payment of the customs dispatch fee (DTA), and guarantees. The A10 form exempts payment of the DTA and allows multiple entries and exits without managing new customs declarations. This generates a debate about fairness: the DTA is paid for customs clearance services, and its selective exemption constitutes preferential treatment compared to national operators.
It is the core of the privilege. It releases individuals and legal entities linked to FIFA from fundamental tax obligations arising from the event, including exemption from Income Tax (ISR) and Value Added Tax (VAT), as well as the waiver of formal declarations and registrations.
The tax benefits of the foregoing include, but are not limited to:
Article 31, section IV of the Mexican Constitution establishes the obligation to contribute to public spending in a proportional and equitable manner.
FIFA is a private association that conducts lucrative commercial activities in Mexico (broadcast rights, sponsorships). Any company engaging in those same activities would be subject to taxation. By exempting FIFA from these burdens, the distinction is not based on a difference in taxable capacity or legal nature, but solely on its identity and its connection to the event.
According to the Supreme Court of Justice of the Nation, to provide different tax treatment, there must be an objective difference that justifies it. The principle of tax equity does not admit exceptions based solely on the taxpayer's identity.
The Mexican state has created a parallel regulatory system for the 2026 World Cup, streamlining procedures, circumventing controls, and forgiving taxes. The technical and legal debate does not lie in whether the state should fulfill an international contract, but in how that fulfillment impacts the pillars of tax law.
The principle of fairness applies to everyone or loses its validity, and that is the main contradiction that FIFA's tax regime leaves as a legacy within the national legal framework.
Maximiliano Muñiz Ayón / Tax Team
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