Fiscal materiality and evidence of actual transactions

Building a traceable record of each transaction

A transaction-substance file should explain what was contracted, who performed it, how it was delivered and how it relates to the company's activity. We review records in that sequence, checking that contracts, CFDI invoices, payments and operational records correspond. The evidence depends on the transaction: a specialized service leaves different records from the purchase and transport of goods through a supply chain.

We identify deliverables, communications, reports, logs and other records already held by the responsible departments. We then assess what each document proves and where gaps or contradictions exist. The work is to organize and explain authentic evidence; producing records that suggest events which never occurred would compromise the defense and the company's legal position, while diverting attention from the actual issue.

We also review the relationship between transactions, their recording and the tax effects claimed. Transaction substance, business purpose and the requirements for a deduction or tax credit raise different questions. Separating them helps answer the authority's actual observation and identify whether the disagreement concerns performance, the transaction's purpose or its treatment in the return, rather than combining distinct issues into one assertion.

Addressing denied deductions or VAT credits

When the SAT issues a request or observation, we study why the authority considers the evidence insufficient. We compare that explanation with what the company submitted and with records that may still be provided at the relevant stage. The response should identify the transactions, describe their performance and connect each statement with the records supporting it, so the dispute remains tied to specific facts.

Objections concerning the supplier's capacity, deliverables or connection with the business need distinct responses. We examine whether the authority alleges specific facts and whether it evaluated the information as a whole. A defense relying only on invoices may leave the operational question unresolved; likewise, providing records without explaining their connection can prevent their evidentiary value from being understood in the case.

If the issue leads to a decision, we assess the available challenges using the file formed during the examination. We also assist with organizing records for future transactions, drawing on information the business produces in its ordinary activity. The aim is to retain a verifiable account of each transaction and reduce reliance on reconstructions attempted years later, when the people and records may have changed.

Frequently asked questions