In brief
Mexico's Tax Administration Service (SAT) published Statement 01/2026 in relation to key points for transparency in Tax Audits.
Key takeaways
1. Master Plan 2026 Released
SAT will publish its strategic plan for taxpayer services and audits, emphasizing transparency and efficiency. In this plan, SAT will communicate the main topics that they will focus audits in 2026.
2. Audit Policy Changes
- Only one audit per taxpayer for non-compliance cases.
- Audits will use sampling methods instead of full reviews to reduce administrative burden.
3. Risk-Based Audit Focus
Priority on taxpayers with:
- Transactions with fraudulent invoice issuers or payroll manipulation services
- Recurrent tax losses
- Simulated deductions, undeclared income
- Misuse of tax incentives
- Mismatched on purchases/imports vs sales
- Imports below market value or violating non\-tariff rules
- Failure to withhold and remit employee taxes
- Payments made or received from tax havens
- Unjustified refunds requests
- Effective tax rates significantly below industry parameters published by the SAT
4. Uniform Application Nationwide
The tax authority will use consistent criteria in audits related to discounts, unidentified deposits, materiality thresholds, marketing expenses, imports, and trade permits.
5. Recommendations
Prepare for risk-based audits by ensuring compliance in high-risk areas.
- Review your defense files ensuring that you have enough evidence to prove substance and business purpose of main deductions
- Determine the effective tax rates of your business in Mexico and compare with SAT expectations
- Review payments to tax havens
As increase in audit activity is expected, we recommend taking the steps above to be prepared for a tax audit. Baker McKenzie has a multidisciplinary team of attorneys, accountants and economists with deep experience in responding to audits in a timely manner. We invite you to schedule a meeting with our team to discuss appropriate compliance strategies for your organization.