The SAT releases its Tax and Collection Program for 2024.


Mexico City, February 12, 2024.

To monitor the correct compliance with tax and customs obligations, the Tax Administration Service («SAT») released its Master Plan for fiscal year 2024.

The strategy of such Master Plan is focused on three main aspects: assistance for taxpayers, collection, and auditing.

Regarding the strategy for collecting and auditing, during this year the SAT will focus its inspections on the following economic sectors:

Automotive industryEntertainment industryMetallurgic industryReal Estate services
Alcoholic beverages and tobaccoPharmaceutical industryCourier and messenger servicePrivate education services
Wholesale and retailHydrocarbonsTechnological platformsPrivate health services
ConstructionHotels and hospitality industryPublicity 
ElectronicsLogistics and transportationInsurance and financial services 

Additionally, the tax and customs authorities will focus their efforts on concepts and conducts of special interest, such as:

  • Use of private pension plans or similar, outsourcing, and Simplified Tax Regime (“RESICO”).
  • Undue application of tax credit balances, 0% VAT rate, no-subject-to-tax VAT activities, and VAT on importation.
  • Corporate restructuring and tax effects of spinoffs, mergers, and international corporate reorganizations.
  • Transfer of shares and intangible assets.
  • Review of partners and shareholders in corporate restructuring transactions.
  • Losses and tax incentives, as well as Preferential Tax Regimes (equivalent to the Controlling Foreign Company rules) or “REFIPRES”.
  • Foreign trade operations.
  • Misuse of treaty benefits and verification of origin.
  • Crediting of the Excise Tax (Special Tax for Production and Services or “IEPS”).
  • Non-compliance with IMMEX Programs, temporary imports, and importation permits.
  • Undervaluation based on incorrect customs valuation, tariff classification, and inconsistent declarations in custom declarations.
  • Financing, capitalization of liabilities, and distribution of profits.
  • Trusts (Fideicomisos) and credit intermediation companies.
  • Fuel volumetric controls.
  • Technology platforms of e-commerce and collection.

The Tax Administration Service will implement several activities, such as:

  • Strengthening assistance to taxpayers.
  • Guidance and assistance to taxpayers on tax deficiencies for the regularization on the payment and the voluntary and timely compliance with their obligations.
  • Applying benefits on audits’ self-corrections.
  • Improvements in tax returns.
  • Using artificial intelligence for a better planning in collection processes as well as reviewing certain topics, such as: outsourcing payroll, undue applications of tax credit balances, foreign trade taxation, among others.

Finally, in order to avoid tax malpractices, the authority will carry out collection and inspection actions tackling irregularities in tax and customs matters, such as:

  • Focusing on taxpayers with tax deficiencies with good collection potential.
  • Strengthening of «persuasive» actions for the collection of tax deficiencies.
  • Increase in collection actions against taxpayers with non-guaranteed tax deficiencies.
  • Coordination with States to increase audits, operations and collection of tax deficiencies.
  • Restriction of digital invoice stamp certificates to taxpayers that simulated transactions.
  • Monitoring taxpayers that failed to comply with tax payment deadlines.

In conclusion, it is clear that, with the Master Plan for the fiscal year 2024, tax authorities aim to continue increasing their collecting efficiency, through auditing and administrative actions, with a special focus in certain industries, concepts and conducts.

The lawyers of the tax and foreign trade practices of the Firm are at your service to assist you to prevent or correct any situation, in connection with the actions of this SAT’s Master Plan for 2024 or to replay any questions regarding its scope and implications for your companies.


Gerardo Nieto

Gil Zenteno

Alejandro Barrera

Víctor Barajas

Sergio Barajas

Francisco Matus

Norberto Ruiz