As in previous years, at the end of January 2023, the Tax Administration Service (hereinafter, “SAT”), published the Fiscalization and Collection Master Plan 2023 (hereinafter, “Master Plan 2023”). In this sense, the Master Plan 2023 has four axes to comply with the economic objectives proposed for the current fiscal year.
Thus, the four axes proposed by the SAT are as follows:
1. Authority management.
Its purpose is to accompany taxpayers for voluntary compliance and to encourage, through vigilance, the regularization of taxpayers who are in default or who present differences.
2. Audit actions.
Through this axis the SAT will combat evasion schemes of invoicing and payroll companies, in addition, it will attack smuggling by strengthening the reviews of foreign trade operations, mainly in temporary imports and verification of origin. Likewise, it will continue to publish effective rates for large taxpayers.
3. Economic sectors to be reviewed.
| Steel | Entertainment |
| Food | Pharmaceuticals |
| Automotive | Mining |
| Beverage and tobacco | Services |
| Trade | Real Estate |
| building | Financial system |
| Electronics | Telecommunications |
| Energy | Stockholding |
4. Concepts and behaviors to be reviewed.
It is important to consider that this Master Plan 2023 specifies the concepts and conducts to be reviewed.
| Misapplication of tax credits. | Corporate restructurings and the tax effects of spin-offs and mergers. |
| Hydrocarbons IEPS supply chain. | Partners and shareholders (individuals in operations associated with restructurings). |
| IEPS credits. | Tax losses. |
| Pensions, payroll exemptions and simulation of rendering of specialized services. | Preferential tax regimes. |
| Refunds, 0% rate, non-object and temporary import. | Financing, capitalization of liabilities and distribution of profits. |
| Undervaluation in foreign trade operations and improper use of treaties. | Foreign payments and international restructurings. |
| Verification of compliance with VAT-IEPS certifications. | Trusts. |
| Mining rights. |
Thus, although the 2023 Master Plan establishes important points to consider, it overlooked the problem of captive taxpayers, which is unfair, since the actions are focused on the control of active taxpayers and do not contemplate actions to attack people who operate informally and do not contribute resources to public spending.
Thus, in case of any doubt or concern related to this issue, the tax team of Vega, Guerrero & Asociados, is ready to provide advice and resolve any inconvenience derived from it.
