Mexico City, February 1st, 2023.

With the intention of overseeing the correct compliance of taxpayers’ tax and customs obligations, the Tax Administration Service (“SAT” according to its Spanish acronym) announced the Tax Auditing and Collection Master Plan for fiscal year 2023.

The coordinated strategy of the Master Plan is focused on the following 4 pillars:

  1. Economic sectors to be reviewed.
  2. Concepts and behaviors to be reviewed.
  3. Authority management.
  4. Auditing measures.

Within 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, pharmaceutical, commercial (retail), beverages and tobacco, mining, real estate services, telecommunications, construction, entertainment, financial system, tourism, hospitality and shareholding.

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

    • Undue application of credit balances;
    • Tax losses;
    • Refunds for: 0% rate, non-object activities and temporary importation of goods;
    • Hydrocarbon supply chain;
    • Preferential Tax Regimes («REFIPRES» according to its Spanish acronym);
    • Undervaluation in foreign trade operations and improper use of treaties (e.g. «treaty shopping»);
    • Excise tax (“IEPS” according to its Spanish acronym) crediting;
    • Pensions, exemptions in payroll and simulation of rendering of specialized services (outsourcing);
    • Verification of compliance with VAT-IEPS certifications;
    • Trusts (Fideicomisos);
    • Mining fees;
    • Corporate restructurings and the tax effects of spin-offs and mergers;
    • Foreign payments and international restructurings;
    • Financing, capitalization of liabilities and profit distribution;
    • Individuals in restructure-related transactions (partners and shareholders).

In accordance with the aforementioned Master Plan, the Tax Administration Service will implement various measures, most notably:

    • Assistance to taxpayers to voluntarily comply with their tax obligations.
    • Oversight to encourage the regularization of taxpayers who are in default or who present discrepancies in their obligations.
    • Optimization of the tax credit recovery process.
    • Coordination with the Mexican States.

Finally, in order to avoid tax violations, the authority will carry out auditing actions aimed toward fighting tax and customs irregularities, such as the following:

  1. Tackling tax evasion schemes involving Simulated Transaction Invoicing Companies («EFOS» according to its Spanish acronym).
  2. Strengthening the review of foreign trade operations, mainly in temporary imports and verification of origin.
  3. Review of evasion schemes involving payroll.
  4. Increased road and warehouse operations to combat smuggling.
  5. Publication of effective tax rates for fiscal years 2020 and 2021.
  6. Analysis and programming of atypical income and expense items.

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

The attorneys of the tax practice of our Firm are at your service to assist you preventively or correctively, in order to address the measures of this Master Plan for 2023 or to answer any questions regarding the scope and implications of said plan, for both you or your companies.


Gerardo Nieto


Gil Zenteno


Alejandro Barrera


Víctor Barajas


Francisco J. Matus


Roberto Serralde