A tax attorney defends companies and individuals before the SAT and other Mexican tax authorities: handling audits and invitation letters, challenging tax assessments through administrative appeals, annulment proceedings, or amparo, and designing compliance strategies that prevent contingencies. At KNR Abogados we combine preventive advice with tax litigation before the TFJA and the federal courts.
When does your company need a tax attorney?
Tax law governs the relationship between taxpayers and the State: federal taxes such as income tax and VAT, local contributions, and social security payments. The Federal Tax Code (CFF) grants the SAT broad audit powers — on-site inspections, desk reviews, and electronic reviews — each with its own rules and deadlines. Getting involved from the first notice, rather than after a tax assessment exists, is what most reduces the cost of a contingency.
Tax defense remedies
Against a tax assessment or an adverse ruling there are three main avenues: the administrative appeal (recurso de revocación) before the authority itself, the annulment proceeding before the Federal Court of Administrative Justice (TFJA), and the amparo action before the federal judiciary. The choice depends on the act, the available evidence, and the overall strategy; the general deadline to challenge is thirty business days, so timing is critical.
Prevention: the best defense
A large part of tax litigation is avoided with preventive hygiene: documenting the substance of transactions, monitoring the article 69-B CFF lists (EFOS/EDOS) where a supplier could appear, complying with beneficial-owner obligations, and documenting the business reasons for restructurings. We also handle conclusive agreements before PRODECON, which allow closing audits with certainty and, where applicable, penalty forgiveness.
This content is informational and does not constitute legal advice. Every case requires individual analysis.
Tax defense before the SAT
Handling of audits, on-site inspections, electronic and desk reviews, invitation letters, and information requests, from the first notice.
Tax litigation
Administrative appeals, annulment proceedings before the TFJA, and tax amparo actions, including suspension of collection enforcement.
Conclusive agreements before PRODECON
Negotiation with the authority during the audit to regularize the tax position with legal certainty and penalty benefits.
Tax advice and planning
Opinions on transactions and restructurings, application of double-taxation treaties, and business-reason analysis, in full compliance with the law.
Refunds and offsets
Recovery of VAT and income tax credit balances, handling of information requests, and defense against denials.
Compliance and prevention
Transaction substance files, monitoring of CFF article 69-B lists, beneficial-owner obligations, and internal protocols to reduce tax risk.
Resolvemos tus dudas
What should I do if I receive an invitation letter from the SAT?
Do not ignore it. An invitation letter is not a formal audit, but it signals that the authority detected inconsistencies. Review the origin of the differences with a specialist before responding or self-correcting: a well-supported clarification can close the matter, while a rushed self-correction can generate unnecessary payments.
How long do I have to challenge a tax assessment?
As a general rule, thirty business days from the date the notice takes effect, both for the administrative appeal and for the annulment proceeding before the TFJA. Letting the deadline lapse makes the assessment final and enables coercive collection, including account seizures.
What is the annulment proceeding?
It is the administrative litigation processed before the Federal Court of Administrative Justice to annul unlawful tax and administrative rulings: tax assessments, fines, refund denials, among others. It can be filed traditionally or online, and allows a stay that halts collection while it is resolved.
Can the SAT freeze my company's bank accounts?
Only in specific cases, such as precautionary attachment or seizure within the administrative enforcement procedure, and under strict requirements that the Supreme Court has narrowed. If it happens, urgent remedies exist — including a stay in amparo — to restore the company's operations.
What is a conclusive agreement and when is it advisable?
It is a mediation mechanism before PRODECON available during an audit, before the assessment is issued. It suspends the audit deadlines, allows negotiating the characterization of the facts with the authority and, the first time, grants the right to 100% forgiveness of penalties.
Anticipate. Protect. Scale.
Free legal assessment
Answer a short questionnaire (under 2 minutes) and our team will send you an assessment of your compliance and a strategic proposal for your operations in Mexico.
