On January 26th, 2026, the Tax Administration Service (“SAT”, per its acronym in Spanish) published its Master Plan for 2026, a document that establishes the tax authority’s strategic guidelines to achieve a historic collection target of 5.8 trillion pesos, strengthen the fight against tax evasion, and improve taxpayer services.
It is structured around three fundamental pillars aimed at transforming the relationship between the tax authority and taxpayers, establishing a voluntary compliance framework with transparent audit criteria and a determined fight against illegal invoicing practices.
Presence and Service Quality
The SAT will expand its territorial presence and improve service quality through:
- Opening of nine new service modules in Baja California, Baja California Sur, Mexico City, Jalisco, Michoacan, Nuevo Leon, Oaxaca, Quintana Roo, and Yucatan.
- Strengthening of the Mobile Office program across all 32 states to bring basic procedures closer, such as Federal Taxpayer Registry (“RFC”, per its acronym in Spanish) registration, electronic signature, and tax returns.
- Implementation of new simplified formats, optimization of service time at the existing 166 offices, and renewal of the Taxpayer Clarification Service (Virtual Office).
- Assistance in compiling documentation for tax refund procedures and expansion of the appointment system for taxpayers under review or audit.
Audit Framework
The SAT establishes specific and public criteria for audit scheduling, focusing on risky behaviors rather than compliant taxpayers.
Audits and reviews will focus on taxpayers who:
- Operate with invoice-selling or fake payroll companies.
- Report recurring tax losses.
- Simulate or illegally apply deductions.
- Obtain undeclared income.
- Abuse tax incentives.
- Present inconsistencies between purchases and sales.
- Imports with undervalued prices or violate regulations.
- Fail to pay employee withholdings.
- Operate through tax havens.
- Request improper refunds.
- Pay lower effective tax rates compared to their sector.
Homogeneous application of procedures across all SAT offices regarding items such as discounts, unidentified deposits, materiality, imports, and nontariff regulations.
Coordinated actions against evasion and smuggling, requesting only strictly essential documentation.
Fight Against the Purchase and Sale of False Invoices
The SAT intensifies its actions against illegal invoicing schemes with decisive measures:
A. Against issuers (invoice-selling):
- Specific domiciliary visits with immediate suspension of operations.
- Criminal complaint before the Public Prosecutor under the new criminal offense.
- Denial of RFC registration when prior participation in companies issuing false receipts is detected.
B. Against recipients (buyers):
- 30-day deadline to correct tax situation after receiving notification of invoices declared false.
- Suspension of invoicing if not corrected within the established deadline.
- Collection of omitted taxes.
Our Tax team is at your service to analyze the specific implications of the Master Plan for 2026 on your operations and develop compliance strategies appropriate to your particular situation.
