US companies have told their government that Mexican tax audits feel inconsistent and that VAT refunds can take up to six months. Mexico’s Finance Ministry (SHCP) has responded with new guidance for the tax authority (SAT).
What the guidance says
- One comprehensive review per fiscal year and per taxpayer.
- No retroactivity: audits follow the rules in force at the time.
- Digital seals (needed to issue invoices) suspended only as a last resort.
Why documentation still matters
The criteria are guidance: they do not create enforceable rights and do not formally limit the SAT, although they can support a defence. The best protection is still a complete file: contracts, proof that services were actually provided, transfer pricing support and reconciled e-invoices.
What to do now
Run a short audit-readiness check on your Mexican entity: pending VAT refunds, intercompany charges, deductions without full support and any open SAT requests.
Sources: El CEO (October 5, 2026), on the US State Department’s 2026 Investment Climate Statement; Foley & Lardner, “New criteria for tax audits and refunds” (May 8, 2026). This note is general information, not legal advice.
