The Fourth Transformation’s tax policy is stricter; It began with the cancellation of forgiveness for large business groups, through a decree published on May 20, 2019. At the same time, the carrying out of audits of previous fiscal years to determine tax credits was strengthened. Those who have not been satisfied have gone to trial fighting battles that have ended with the resolution in favor of the treasury by the Supreme Court of Justice of the Nation, as happened recently in the case of the tax debts of Ricardo Salinas Pliego’s companies.
The highest percentage of trials won by the tax authority also reflects the implementation of the SAT Master Plan, which began in 2019, and which year after year has reinforced the authority’s precision shots, with the implementation of technology and AI, for the control of resources through audits. Also greater training and experience for its lawyers, explained Luis Pérez de Acha, founding partner and director of the Pérez de Acha e Ibarra Rueda law firm.
“It is a reality that the treasury defends itself better and better, in another era, the success rate of taxpayers was much higher, because the treasury did not have good defense teams, that has been reversing over time, because they prepare more and more, each time they litigate matters in a way that is litigated on the side of private initiative. Before, the way in which they litigated was very bureaucratic, they let the matters be conducted almost on their own; not now, now they have a lot of presence in courts, visiting judges, magistrates, and ministers, as individuals do when we litigate any matter,” explained Pablo Puga Vértiz, member of the National Fiscal Commission of the Mexican Institute of Public Accountants (IMCP).
Treasury figures detail that for each trial won in 2018, the authority recovered 12.8 million pesos, while in 2025 it recovered 23.5 million for each trial in favor, that is, 45.5% more in seven years.
