Defense against SAT tax assessments and penalties

Reviewing the decision and the basis of the liability

We start with the complete decision and proof of service. We identify the taxes, periods, inflation adjustments, late payment charges and penalties included, together with the transactions the authority questions. The analysis distinguishes calculation errors from issues concerning legal grounds, reasoning or procedure. This separation supports specific arguments and avoids treating the total amount as though it arose from a single cause.

We compare the authority's factual findings with the audit file, tax returns and the company's supporting records. We examine what evidence was submitted, how it was assessed and whether observations remained unanswered. The defense must explain why an item is unjustified or why the act has a legal defect, with references to the case rather than general wording or an unsupported disagreement with the amount.

The date and method of service are part of the diagnosis. We also check for collection steps and which obligations have been met or remain outstanding. Gathering these records at the outset allows us to assess time limits and the effects of each option without confusing the dispute over the liability with the steps required to address its enforceability.

Challenging the assessment and addressing its effects

We examine whether an administrative appeal or proceedings before the Federal Court of Administrative Justice are available. The choice depends on the act, the background and the evidence strategy. We explain which issues can be disputed through each route and the requirements to meet, so the business can assess its defense with an understanding of the procedure and the records needed.

Penalties need a separate review even when they accompany a tax assessment. We analyze the alleged conduct, the provision applied and the reasoning behind the sanction to identify defense arguments. Where several decisions are connected, we coordinate their review to maintain a consistent position and prevent attention to one decision from overlooking other acts that also affect the taxpayer.

Filing a challenge and obtaining a stay of collection are matters that need separate assessment. We evaluate security requirements and interim measures relevant to the case file. The strategy includes monitoring later procedural steps, reviewing information requests and keeping the business informed of effects that remain in force while the dispute is decided, so operational decisions reflect the actual legal position.

Frequently asked questions