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In brief

Recently, Mexican tax authorities have not only been increasing the number of tax audits conducted to review the due compliance with tax obligations, but they have also been more aggressive using new tools to secure higher collection in taxes.

The Mexican President mentioned that they have a list of taxpayers that owe the Mexican Government more than MXN 50,000 Million (USD 2,235,960,000). This list does not include taxpayers currently facing a tax audit. Because of this, the Mexican IRS (SAT) has begun many tax audits or is directly requesting taxpayers to file amended tax returns due to allegedly illegal deductions.

It has recently become more common that taxpayers receive an ‘invitation letter’ by which tax authorities begin an express informal revision. It should be a top priority for companies to be prepared for a tax audit. It does not matter if the Mexican company of the group has been recently incorporated or it is now a large taxpayer, the key question is “how the company can be prepared for a tax audit?”

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Roxana Massiel Gómez Orta has been recognized as one of Mexico’s leading tax lawyers by Defensa Fiscal and International Tax Review in their Tax Controversy Leaders and Women in Tax Leaders editions. She joined the Firm in 2001, and was appointed a national partner in July 2007. Roxana has more than 20 years of professional experience, and is currently a member of the Firm’s Tax Practice Group, which has been recognized as a highly recommended global tax practice by Chambers Global. She is also a member of the Academia de Derecho Fiscal de Nuevo León, A.C and was appointed as a member of the board, acting as the treasurer during 2008-2009 and as advisor during 2015-2016. She has published articles in Defensa Fiscal, IDC Asesor Jurídico y Fiscal, Puntos Finos, Players, Práctica Fiscal, Corporate Business Taxation Monthly, Maquila Reynosa, Inter-American Trade Report and Tax Notes International, among others.


Luis Adrian is the head of the Mexican Tax Practice Group, a member of the North America Management and of the Latin American Tax Steering Committee. Since joining the Firm in 2004, Luis Adrian has advised clients from a range of different industries, focusing on Mexican inbound planning for North American and European headquartered multinationals and multijurisdictional group reorganizations and restructurings. He is both a CPA and a lawyer.