Go to main content

SAT strategic plan, more aggressive with the righteous, turning a blind eye to sinners: Santamarina and Steta

May 10, 2022 /
  • They are going to invest significant resources in oversight and they are not going to find much, while the big evaders persist and the informal economy grows..
  • Nothing to increase the taxpayer base.

CDMX. May 4, 2022. Mariano Calderon, Partner in charge of the firm's tax area Santamarina and Steta He pointed out that the Strategic Plan for Large Taxpayers presented a few days ago by the SAT confirms the view that captive taxpayers, those who already pay, will continue to be exploited, without really taking a fundamental measure to address the country's major fiscal problems.

“The problem is that large taxpayers already pay their taxes according to the law and what is coming are lengthy reviews, litigation and loss of time that will not leave much more revenue for the SAT. They are guided by the false dogma that large companies in Mexico do not pay taxes and they are going to come up against the reality, which is very different, given that in Mexico 20% of total revenue comes from corporations, which places us as the seventh country with the highest corporate revenue within the OECD, while we continue to have a huge fiscal gap derived from the invoice companies and the formal economy that continues to grow, without any fiscal consequences,” reported.

Mariano Calderón clarified that with the strategic plan, tax litigation will increase, given that large taxpayers have the right to demonstrate that their operations comply with the law and not accept unfounded assumptions from the SAT, so that it is the courts that decide in light of the law and the truth, no matter how aggressive the criteria of the authorities may be. “The problem is doctrinal, dogmatic, that companies do not pay and that the government requires resources, even when the latter are squandered on projects without social and economic profitability. But before the law, we all have rights and obligations. They want to increase the tax burden on large taxpayers without collecting taxes from the bulk of informality,” clarified.

According to the expert, toughening the criteria for large corporations will eventually end up reducing their capacity for investment and job creation and the detonation of production chains, creating a vicious circle against economic growth. “Unfortunately, we believe that the already strong wave of acts of supervision, persecution and audits of large corporations will increase, and will be fought in court.” concluded.


Mexico City Office

Tel. +52 55 5279 5400

Monterrey Office

Tel. +52 81 8133 6000

Queretaro Office

Tel. +52 442 290 0290

Related articles

Santamarina and Steta Infrastructure Promotion Law

The Law for the Promotion of Investment in Infrastructure is enacted…

On April 9, 2026, the Decree issuing the Law for the Promotion of Investment was published in the Official Gazette of the Federation…
shutterstock 2696150007

Amendments to Article 141 of the Federal Tax Code…

On April 9, 2026, the Decree reforming Article 141 of the Federal Tax Code was published in the Official Gazette of the Federation…
Site Update (1)

CFE Portfolio 2026-2027: 58 projects to strengthen the tra…

Executive Summary On March 22, 2026, the Federal Electricity Commission (“CFE”) presented its “Transmission Project Portfolio…”