SAT Surpasses Revenue Target with Big-Taxpayer Audit Collections

Mexico's Tax Administration Service (SAT) collected MX$300.47 billion (US$16.4 billion) in secondary revenue through audits and enforcement actions targeting large taxpayers in the first nine months of the year, 4.3 times higher than the MX$69.58 billion goal set by the Ministry of Finance and Public Credit (SHCP).

The results reflect the federal government’s strategy to increase collections from large corporate and individual taxpayers, defined as those with annual income above MX$1.5 billion.

Record Collections and Policy Drivers

Compared with the same period last year, revenue from audits and tax-credit determinations rose 23.3% in nominal terms. The amount is also 5.5 times higher than what was collected from January to September 2018.

SAT reported that as of the end of 2024, Mexico had 16,131 large taxpayers. Although they represent just 0.02% of all taxpayers, they generate more than 52% of federal tax revenue. Many of these entities, mainly major corporations, are responsible for withholding and remitting VAT paid by consumers.

The continued increase in collections is attributed to the administration’s decision to end historic tax-forgiveness practices for large companies, which were traditionally granted at the start of each presidential term. The current policy relies heavily on audits of prior fiscal years to recover unpaid taxes related to large transactions, transfers, and corporate restructurings.

Targeted Audits and Efficiency Gains

Authorities say improvements in digitalization and the use of artificial intelligence (AI) have enabled more targeted audits.

Key indicators include:

• Efficacy Rate: SAT aimed for 68.5% of in-depth reviews to result in collections exceeding MX$100,000. The actual rate reached 76.4%, surpassing the target by 11.6 percentage points.

• Average Collection: The average amount collected per enforcement action was MX$254.8 million through September—the third-highest figure for the same period in the last six years.

Large taxpayers are primarily concentrated in services and industrial sectors, spanning retail and wholesale trade, transportation, financial services, manufacturing, and the supply of electricity, water, and gas.

Tax Litigation and Resolution

Once tax debts are determined, taxpayers may pursue legal avenues, primarily lawsuits, to contest the charges. Since 2023, an increasing share of these cases has been resolved in favor of SAT.

The most recent high-profile example involves Grupo Salinas, led by businessman Ricardo Salinas Pliego. On Nov. 13, the Supreme Court rejected amparo petitions filed by Grupo Salinas and Elektra related to Income Tax (ISR) debts. With penalties and surcharges, the amount owed is expected to exceed MX$50 billion.