January 27, 2026

On January 26, 2026, the Tax Administration Service («TAS») announced, among other things, the main actions on which they will focus their tax audit efforts during the current fiscal year.
It is indicated that those taxpayers who carry out the following behaviors will be audited:
- Carry out operations with companies that issue false invoices or carry out abusive payroll schemes.
- Reporting tax losses on a recurring basis.
- Simulation and application of unduly deductions.
- Do not report all income.
- Abuse of tax incentives.
- Have inconsistencies between imports, purchases and sales.
- Import products using below-market prices and fail to comply with non-tariff regulations or restrictions.
- Not paying income tax withholdings on salary payments to employees.
- Carrying out operations through persons or companies located in preferential tax regimes (tax havens).
- Requesting unduly tax refunds.
- Having an effective income tax rate lower than that published for their sector of activity.
It is also established that uniform criteria will be applied in the different TAS offices at the national level to attend to audits, paying special attention to the following concepts:
- Discounts
- Unidentified deposits
- Materiality of operations
- Marketing expenses
- Import operations
- Non-tariff regulations
- Permissions
- Certifications
- Foreign trade authorizations
Finally, it is pointed out that tax authorities will direct their efforts in inspection actions to identify, dismantle and punish tax evasion and sham schemes, as well as tackling those who produce and buy false invoices, through agile audits and filing criminal complaints against the alleged liable.
The lawyers of the Basham tax area are at your disposal to assist you, preventively or correctively, in the aspects that will be reviewed as part of the TAS Master Plan for 2026.
SINCERELY:
Gerardo Nieto
Gil Zenteno
Alejandro Barrera
Sergio Barajas
Victor Barajas
Ramón de la Torre