The Mexican Tax Administration Service (SAT) has implemented changes effective January 1 to tackle fake invoices, applying to individuals and entities with a focus on tax evasion. These measures ensure due process without preventive prison or automatic bank account freezes. The goal is to provide certainty to compliant taxpayers while targeting specific noncompliance risks.
The SAT has clarified that the introduced changes do not amount to a massive crackdown on compliant taxpayers, but rather a targeted effort against tax evasion. According to the official statement, due process and the right to a hearing will be upheld, preventing affected parties from being defenseless. Taxpayers can secure fiscal interest based on their economic capacity through options such as deposit bills, pledges, mortgages, letters of credit, bonds, or administrative seizures.
Fake invoices now encompass not only fabricated ones but also those backing nonexistent or simulated operations. Any invoice will be deemed invalid if the movement or service cannot be proven to have actually occurred. For 2026, the SAT plans to initiate approximately 16,200 audit processes, based on analyses of transactions and inconsistencies, rather than randomly.
Audit criteria include dealings with invoicing companies, recurrent fiscal losses, simulation or abuse of deductions, undeclared income, misuse of fiscal incentives, discrepancies between imports and sales, imports at below-market prices, failure to pay employee withholdings, operations with tax havens, improper refund requests, and effective tax rates lower than required. These reviews aim to identify noncompliance risks and have emerged amid rumors of arbitrary detentions, which the SAT has refuted, offering advisory services during winter vacations.