On October 20, 2025, Mexico’s Tax Administration Service (SAT) published new audit selection criteria for 2026 as part of its ongoing transparency efforts and aims to ensure fair treatment across taxpayers.
Position
Mexico’s Tax Authority emphasized that it will only audit taxpayers identified as high risk based on specific fiscal conducts. These include simulated deductions, recurring tax losses, abuse of tax incentives, undeclared income, operations involving tax havens, the use of fake invoicing or payroll outsourcing companies, and paying an effective tax rate lower than that of the taxpayer’s sector, among other situations.
Outcome
Based on these risk-based criteria, the SAT plans to audit 16,200 taxpayers in 2026, broken down as follows:
1,200 large taxpayers (6.3% of the total registered)
12,000 small and medium-sized enterprises (0.02% of SMEs)
3,000 foreign trade operators (2.5% of the sector)
Key Takeaways
Targeted audits: The tax authority will conduct audits only on taxpayers exhibiting high-risk tax practices, identified through specific risk indicators.
Scrutiny of tax schemes: Priority will be given to auditing taxpayers with recurring tax losses, abuse of deductions, improper use of tax incentives, undeclared income, or effective tax rates lower than those of their sector.
High-risk taxpayers: Priority will be placed on reviewing large taxpayers and foreign trade operators with elevated risk levels.
Strategic priority for 2026: It is highly advisable to review internally your company’s tax positions and identify potential risks to mitigate contingencies in the event of an audit.
Contact BaseFirma to ensure tax compliance and efficiency in your related-party transactions.
For more information:
Omar López: Omar.lopez@basefirma.com
Julian Del Toro Avila: Julian.DelToro@basefirma.com