Mexico City, January 30, 2023.

In order to monitor the correct compliance of taxpayers' tax and customs obligations, the Tax Administration Service announced the Fiscal and Collection Master Plan for fiscal year 2023.

The Master Plan's coordinated strategy is focused on the following 4 axes:

  1. Economic sectors to be reviewed.
  2. Concepts and behaviors to be reviewed.
  3. Authority management.
  4. Audit actions.

Taking into consideration the above, in the SAT's auditing strategy, there are economic sectors of special interest for the reviews to be carried out by the tax authority, among them: food, steel, automotive, energy, electronics, electronics, pharmaceutical, commercial (retails), beverages and tobacco, mining, real estate services, telecommunications, construction, entertainment, financial system, tourism, hospitality and shareholdings.

With respect to these sectors, the conducts of special interest for the tax-customs authority will be related to the following concepts:

    • Misapplication of credit balances;
    • Tax losses;
    • Refunds for: 0% tax, non-object activities and temporary importation of goods;
    • Hydrocarbon supply chain;
    • Preferential Tax Regimes ("REFIPRES");
    • Undervaluation in foreign trade transactions and improper use of treaties (e.g. ".treaty shopping");
    • IEPS credit;
    • Pensions, payroll exemptions and simulation of specialized services rendered;
    • Verification of compliance with IVA-IEPS certifications;
    • Trusts;
    • Mining rights;
    • Corporate restructuring and the tax effects of spin-offs and mergers;
    • Foreign payments and international restructurings;
    • Financing, capitalization of liabilities and distribution of profits;
    • Individuals in operations associated with restructurings (partners and shareholders).

In accordance with the reiterated Master Plan, the Tax Administration Service will implement several actions, among which the following stand out:

    • Accompanying taxpayers for voluntary compliance with their tax obligations.
    • Surveillance to encourage the regularization of taxpayers who are in default or who present differences in their obligations.
    • Optimization of the tax credit recovery process.
    • Coordination with the country's states.

Finally, in order to prevent tax malpractices, the authority will carry out auditing actions aimed at combating irregularities in tax and customs matters, such as:

  1. Combating evasion schemes involving Simulated Transaction Invoicing Companies ("EFOS").
  2. Strengthening the review of foreign trade operations, mainly in temporary imports and verification of origin.
  3. Review of corporate avoidance schemes involving "nomineras".
  4. Increased road and warehouse operations to combat smuggling.
  5. Publication of effective rates for fiscal years 2020 and 2021.
  6. Analysis and programming of atypical income and expense items.

Thus, it is clear that through the Fiscal and Collection Master Plan for fiscal year 2023, the authorities seek to continue increasing collection efficiency through fiscal and management actions, focusing this year on certain specific industries and activities.

The lawyers of the tax area of the Firm are at your service to assist you preventively or correctively, to address the actions of this Master Plan of the SAT for 2023 or to answer any questions regarding the scope and implications of the same, for you or your companies.


Gerardo Nieto


Gil Zenteno


Alejandro Barrera


Sergio Barajas


Victor Barajas


Francisco J. Matus


Roberto Serralde