Defense in SAT tax audits and examinations

Handling the audit from the first notice

We review the order, information request and proof of service to identify the authority involved, the taxes and the periods covered. The scope of an on-site inspection, desk review or electronic examination determines how the procedure should be handled. From those details, we organize pending steps and identify the records that the business needs to locate and explain.

Information submitted during an audit must be consistent with accounting records, tax returns and business activity. We coordinate legal analysis with the departments producing the records to explain questioned transactions and identify discrepancies before responding. A collection of unrelated files makes a defense harder; the case file should trace each fact, its supporting documents and the tax treatment applied.

We also examine the authority's procedural steps and how it requests or evaluates information. Recording what was submitted, when it was received and which observations remain unresolved helps maintain an organized defense. That record matters during the audit and when assessing any later decision and the remedies that may be available to challenge it on procedural or substantive grounds.

Observations, evidence and resolution options

An observations notice or a final partial audit report requires checking which facts the SAT alleges and what supports them. We separate documentary objections from disagreements over legal interpretation. Each point needs relevant evidence and arguments suited to the procedure, without assuming that a larger volume of records can replace a clear account of the transaction and its treatment.

We assess whether the conditions exist for a PRODECON settlement agreement or for regularizing specific aspects of the tax position. The choice depends on the audit stage, the nature of the disagreement and the available evidence. Before selecting a route, we explain its scope and the consequences for the facts or items being examined, including matters that remain disputed.

If the authority issues a tax assessment, the audit file becomes the basis for considering a challenge. The strategy therefore begins during the examination: identifying omissions, retaining procedural records and submitting evidence at the appropriate stage avoids having to reconstruct the case only after the decision arrives. We assist with that transition from the administrative review to dispute proceedings.

Frequently asked questions