Defense under Article 69-B of Mexico's Federal Tax Code

Identifying the allegation and procedural stage

The analysis starts by distinguishing whether the company is the identified issuer or a taxpayer that dealt with a questioned supplier. That difference determines which facts need review and which procedural steps matter. We examine notices, publications and background records to identify the stage and related invoices, without assuming that every situation described as an EFOS or EDOS case receives the same treatment.

When the authority alleges a lack of capacity to carry out transactions, we review the material and human resources connected with performance. Contracts, premises, assets, staff and activity records must be assessed against the actual business model. The aim is to address the facts behind the presumption and explain how the invoiced services were performed or goods delivered in the transactions being questioned.

For invoice recipients, we define the transactions and tax effects in dispute. We review their own contracting, receipt and payment evidence, together with the commercial relationship with the supplier. The third party's published status and the company's evidence are considered together, but they come from different sources and should not be confused when preparing the response or evaluating a later decision.

Evidence of transactions and defense of their tax effects

We organize a file that traces each transaction from its origin through performance. Records are connected with the facts they establish, including deliverables, movement of goods, communications and relevant accounting entries. Identifying what each record proves helps answer specific objections and prevents the defense from relying on a collection of unexplained files or broad assertions about the commercial relationship and the supplier's conduct.

We review the opportunities to submit evidence and have it assessed at the relevant stage. We also analyze consequences for deductions, VAT credits and other proceedings the authority may have started. The strategy considers these connections to maintain a coherent position across case files, without transferring arguments automatically from one procedure to another or overlooking the requirements that govern each separate proceeding.

When a decision affects the taxpayer, we assess a challenge and any effects that remain in force. In parallel, preventive supplier review can help organize records for later transactions. That review requires retaining actual evidence and checking the supplier's status, without treating a list check as complete proof of the company's transaction or as a substitute for documenting how the goods or services were received.

Frequently asked questions