The SAT’s Aggressive Tax Enforcement: A Growing Concern for Mexican Taxpayers

Web Editor

October 22, 2025

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Introduction

In recent years, Mexican taxpayers have experienced a significant increase in the exercise of verification powers by the Servicio de Administración Tributaria (SAT). High-profile tax cases, such as those of Grupo Elektra and Samsung, which is even considering closing its operations in Mexico, are just the tip of the iceberg. The SAT’s hardline approach is evident in official figures.

Revenue Collection and SAT’s Intensified Oversight

According to public reports from the authority, the collection of income tax for corporations in March 2025 amounted to 390,950 million pesos, a 52% increase from the 256,293 million collected for the same month in the previous year. However, beyond revenue collection, taxpayers feel an increasingly rigorous oversight and tracking of their operations by the SAT, more so than ever before.

This is not limited to large taxpayers; even common individuals and Micro, Small, and Medium Enterprises (Mipymes) frequently receive communications and invitations to pay alleged tax differences, likely generated by the AI the SAT announced in May 2024. While AI benefits the state, its regulation seems less urgent.

Impact on Accountants and Taxpayers

As SAT’s practices become normalized, accountants grow frustrated not due to a lack of accounting knowledge or experience but because the authority changes its criteria daily. Even simple tax filings have become a genuine challenge, as new requirements are increasingly demanded at the SAT’s discretion.

Legal Reforms Empowering the SAT

The government, through legal reforms, has equipped the SAT with various legal powers and tools to continue revenue collection, regardless of the cost. Reforms to the Amparo Law make it more difficult for individuals to win tax lawsuits and significantly reduce the chances of suspending collections while a lawsuit is resolved.

With the reform to the Federal Tax Code, the SAT will have real-time access to taxpayer information from digital platforms. The 2026 Economic Package, already approved by the Chamber of Deputies, has increased taxes on sugary drinks, tobacco, violent video games, museum entrances, and further diversified the SAT’s revenue model.

With these developments, only a reform remains for the SAT to request Guardia Nacional support for tax collection enforcement.

Taxpayer Concerns and Government Response

While the SAT’s strike could be seen as a legitimate protest against abuses and arbitrariness in revenue collection, taxpayers are primarily concerned with labor rights, threats of dismissal, and excessive work hours. There are no signs of government restraint in implementing tax collection policies.

Although revenue collection is crucial for the state, not all taxpayers are fiscal evaders, and not all SAT-determined tax credits are legal. The abuse of revenue collection powers also affects common taxpayers and microenterprises, and the lack of fiscal regulation certainty can discourage investment and even cause disinvestment, creating a counterproductive effect for the very state collecting revenue.

Key Questions and Answers

  • What is the SAT’s role? The Servicio de Administración Tributaria (SAT) is Mexico’s tax authority responsible for tax collection, verification, and enforcement.
  • Why are Mexican taxpayers concerned? Taxpayers are worried about the SAT’s increasingly aggressive enforcement, frequent changes in criteria, and the lack of regulation surrounding AI-generated tax assessments.
  • What legal reforms have been implemented? Legal reforms have given the SAT more powers, made tax lawsuits harder to win for individuals, and allowed real-time access to taxpayer information.
  • What are the SAT’s strike demands? The SAT’s strike involves labor rights concerns, threats of dismissal, and excessive work hours.
  • How does the SAT’s behavior impact taxpayers? The abuse of revenue collection powers affects common taxpayers and microenterprises, potentially discouraging investment and causing counterproductive effects for the state.