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PAGAZA

Tax defense and advisory

Digital seal restrictions and CSD defense

A digital seal certificate restriction can affect CFDI invoicing and business operations. We review the grounds cited by the SAT and assist with the relevant clarification or defense, distinguishing a temporary restriction from a decision that renders the certificate ineffective.

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Assessing the act affecting invoicing

The notice identifies the measure taken by the authority and the facts it considers irregular. We review the legal basis, proof of service and background to determine whether this is a temporary CSD restriction or another situation. The distinction matters because steps to clarify an irregularity cannot be treated as interchangeable with remedies against a decision affecting the certificate's validity.

We compare the stated grounds with the company's returns, invoices and records. Depending on the case, this may involve checking information discrepancies, compliance with obligations or the background of other proceedings. The analysis must address the notice's specific grounds; submitting unrelated documents can consume time without resolving the issue that led the authority to restrict use of the certificate for invoicing.

Coordination with accounting and operational departments helps gather records and understand the effect on invoicing. We retain requests, filing receipts and communications to establish what has been submitted and what remains pending. That record supports follow-up and assessment of later decisions, with an accurate account of the taxpayer's steps and the information available to the authority during the clarification process.

Clarification, follow-up and defense options

We prepare the response around irregularities that can be corrected and grounds that can be rebutted with evidence. The clarification should explain what changed, which information is correct and how it is established. We review the applicable filing requirements and organize supporting records so each document helps answer the observation, rather than merely describing the measure's financial impact on the company.

We follow information requests and the SAT's assessment of the material submitted. The business needs to know the procedural status and any steps required to maintain its position. We do not offer a restoration date without reviewing the legal situation and case file: the outcome depends on the grounds, the evidence and the decisions issued by the authority during the procedure.

If the restriction persists or an adverse decision is issued, we examine available remedies and the requirements for interim measures. We also review connections with audits or nonexistent-transaction proceedings where these form part of the background. Addressing the CSD requires considering those relationships, so responses in separate files do not contradict each other or leave the underlying cause of the problem unresolved.

Frequently asked questions

What should I do if my digital seals were restricted?

Obtain the notice and proof of service, identify the grounds and gather related records. That information allows assessment of the applicable clarification procedure or defense and the steps that need attention.

Are temporary restriction and CSD cancellation the same?

They are different situations. Reviewing the act received identifies the measure taken by the authority and the procedure needed to clarify or challenge it.

Let us review your tax situation.

Tell us about the notice you received or the transaction you need to review. The initial conversation is confidential and without obligation.

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