SAT Strengthens Transparency and Redefines the Approach to Tax Audits in Mexico
Jan 8, 2026
The Mexican Tax Administration Service (SAT) announced a set of best practices aimed at enhancing transparency in tax audit processes, as part of the 2026 Master Plan: Taxpayer __Assistance and Audits__, with the objective of providing greater legal certainty, administrative efficiency, and fairness in tax enforcement actions.
This announcement confirms a structural shift in the way the tax authority exercises its audit and verification powers: tax enforcement is moving away from a generalized approach toward a __selective, technical, and risk-based model. __
Key Measures Announced by the SAT
1. More focused audits
When potential non-compliance is identified, the authority will seek to conduct a single comprehensive audit per taxpayer, avoiding multiple reviews of the same facts and tax periods.
2. Review based on representative samples
Audits will be carried out through the request of representative samples of transactions, rather than requiring 100% of the documentation, thereby reducing administrative burdens and review timelines.
3. Nationwide uniform criteria
The SAT will apply standardized criteria across all its offices, particularly in sensitive areas such as:
- Unidentified deposits
- Discounts and rebates
- Marketing and advertising expenses
- Imports and non-tariff regulations
- Relevant income, deductions, and tax credits
4. Improved tax refund timelines
The authority reiterated its commitment to expediting tax refunds, with estimated average processing times of:
- 5 days for individuals
- 30 days for legal entities (companies)
Risk-Focused Tax Enforcement
The SAT reported that, during 2026, audits will be primarily directed at taxpayers engaging in conduct considered to pose a high tax risk, including, among others:
- Entering into transactions with shell invoicing companies or payroll outsourcing schemes.
- Reporting recurrent__ tax losses without economic__ justification.
- Simulating or abusing tax deductions.
- Earning undeclared income.
- Abusing tax incentives or benefits.
- Showing inconsistencies between imports or purchases and reported sales.
- Importing goods at prices below market value and failing to comply with non-tariff regulations or restrictions.
- Failing to remit payroll tax withholdings.
- Conducting transactions with low-tax or no-tax jurisdictions (tax havens).
- Requesting improper tax refunds.
- Paying taxes at an effective tax rate significantly lower than the average for their industry.
Key Message for Taxpayers
The tax authority has been clear: tax enforcement in Mexico will be more technical, more selective, and more financially efficient for the State. As a result, the economic substance of transactions, consistency between CFDIs, tax returns, and the underlying business reality, as well as robust supporting documentation, will be critical to mitigating tax risks
Official SAT Announcement
The full official announcement may be consulted at the following link:
