Immediate deduction for fruit packing house machinery: 86%, 83%, 67% or 62% depending on your activity

Before the percentage comes a question: which activity brought in most of your revenue in the year you apply the deduction? That answer decides whether the immediate deduction for fruit packing house machinery is 86%, 72% or 67% in 2026, according to the Plan México decree (DOF, Mexico’s official federal gazette, January 21, 2025, Article Two, subsection II).

This article is not tax advice. It is written so you can reach your accountant with the questions already prepared, and your accountant validates your case. If the purchase goes with a loan or a lease, that part continues in robot financing.

Fruit packing house machinery: immediate deduction by year

The percentages come from the decree, and the last column from art. 35 of the Ley del ISR, Mexico’s income tax law. It applies to new fixed assets acquired through September 30, 2030, and the decree calls new those used for the first time in Mexico (Article One). It can be taken by legal entities (personas morales) under Title II or Title VII, Chapter XII, of the ISR Law, and by individuals (personas físicas) under Title IV, Chapter II, Section I.

Office furniture, combustion-engine cars, armoring and any asset that cannot be individually identified are left out. That is why it helps for the cell to arrive with a nameplate and a serial number, and for the invoice to show them.

Which line applies to my packing house?

The decree says that, if you engage in two or more activities, you apply the percentage of the one where you earned most of your revenue in the tax year of the deduction. The Código Fiscal (CFF), art. 16, subsection III, Mexico’s federal tax code, treats as agricultural the planting, growing, harvesting and first sale of products without industrial processing.

This table is Agro Robotics’ reading, for you to take to your accountant. The final call belongs to your accountant and to the authority.

A packing house with its own orchard that, in a poor harvest, went out to buy fruit at the orchard gate has its doubt right there. A year when you bought more fruit from third parties can move you to a different line.

What do you need to apply it?

Five requirements from Article One: being in the RFC, Mexico’s federal taxpayer registry, with a tax mailbox (buzón tributario), a positive tax compliance opinion (CFF, art. 32-D), an investment project, a certificate (constancia) from the Comité de Evaluación, the decree’s evaluation committee, and compliance with its guidelines.

The guidelines of March 21, 2025 say how to request it: a free-form letter filed at the single window (Ventanilla Única) of Hacienda, Mexico’s finance ministry, with proof of tax status (constancia de situación fiscal), the positive opinion, identification, notarized power of attorney, the employer and worker social security contribution statements for the previous three months and the annual returns for three tax years. The project goes down to detail per asset (guideline 13): type and characteristics, amount before VAT (IVA), deduction rate, domestic or foreign origin, date of acquisition and start of use, place of installation, reason for the purchase and the activity it will be used in.

That total leaves out the time to make corrections if they ask you for something. If three months pass from the application without a certificate, it is understood as denied (guideline 12). Whether it makes sense to request it before invoicing is for your accountant to define. If the machine has to be ready for the start of the season, the paperwork gets counted together with the manufacturing. The calendar by crop is in when to install machinery in a fruit packing house.

There is also a cap: up to 30 billion pesos in total while the decree is in force, of which up to 28,500 million are for this deduction and at least one billion for those with revenue of up to 100 million pesos the year before; the Committee also sets a maximum per tax year (Article Five). We did not find how much remains available.

And there are obligations afterward: exclusive use in your activities, at least two years in use after the tax year of the deduction, a specific record of the investment and documentation kept for five years. Whoever fails to comply pays the tax with inflation adjustment and surcharges (Article Seven).

Is it a discount or only an earlier deduction?

It brings it forward. You deduct a percentage all at once, and the rest of the amount stays out until the machine is sold, lost or no longer useful, with the tables in Article Three, subsection III. If you sell it, everything you receive counts as gain (subsection II).

Per MXN 1,000,000 of investment, with ISR (income tax) at 30% for legal entities (ISR Law, art. 9). The million is only there to make the math easier.

Agro Robotics calculation, with a full year of use, enough profit and without inflation adjustment. You pay less ISR in the first year and you give up deducting the rest year after year.

For cash flow there is a useful detail: the decree lets you subtract the deduction in equal parts in your provisional tax payments, starting in the month of the investment, and that is where you feel it in cash before the annual return. If that year there is no profit to reduce, the question is a different one and it goes to your accountant. The payback calculator works for the operating math, and the tax effect goes on top of it. To see what the price of the machine depends on, there is the cost to automate a fruit packing house.

What about the 2027 ISR reform?

As of November 4, 2026 it stands like this: the Senate approved the ISR Law on October 27 with one change and sent it back to the Chamber of Deputies (Proceso). The Chamber of Deputies endorsed that change on November 3 and the bill went to the Executive (El Universal). We did not find it published in the DOF, and we have not read its final text.

What is known comes from the proposal and from professional firms. DFK says the incentive would move to transitory provisions of the ISR Law, for assets acquired from January 1, 2027 to September 30, 2030, with the certificate as a prior requirement. Expansión reported 83% for agricultural machinery in that proposal.

The same reform sets a limit on deductions for legal entities with taxable revenue (ingreso acumulable) above MXN 50 million. Holland & Knight describes, based on the proposal, an exclusion for those who apply the immediate deduction, only with respect to that benefit, and DFK lists exceptions for agricultural and livestock activities. Neither explains how they combine. Meanwhile, the published reference is still the decree, with 83% and 62% from 2027 to 2030. If you buy in 2027, have your accountant read the published text before you sign.

What if the machine is bought on credit or leased?

The decree does not mention leasing. Our reading, for your accountant to confirm: the deduction is taken by whoever owns the asset, so with a loan you are the one who analyzes it, and with an operating lease the lessor analyzes it while you deduct the lease payments. Ask this before you choose a structure, because it changes the math.

What to ask for in the quote

Ask your supplier for a quote that already carries what guideline 13 requires: each asset listed separately, with description, amount before VAT, origin, estimated date of delivery and start of use, and place of installation. With that document your accountant puts together the investment project and defines your line.