The “Master Tax Audit Plan 2025” presented by the SAT prioritizes three key areas: taxpayer assistance, support for compliant taxpayers, and tax enforcement against evasion and smuggling. To achieve this, the SAT has increased the use of technological tools and artificial intelligence in audits, focusing primarily on compliance with transfer pricing obligations.
Companies engaged in transactions with related parties, both domestic and foreign, must ensure timely compliance with their tax obligations, including:
- Supporting documentation (Transfer Pricing Study, detailed functional analysis, and supporting documentation for transactions).
- Informative tax returns (local, master, and country-by-country reports), which must be submitted by May 15 and December 31.
- Multiple Informative Return, as well as the ISSIF annexes and/or tax report.
Additionally, the SAT has intensified monitoring in sectors and transactions it considers high-risk for tax evasion and enforcement, such as intercompany financing, corporate restructurings, transfers of intangibles, among other strategies that tax authorities may classify as aggressive tax planning schemes.
Some examples of Non-Binding and Normative Criteria related to related-party transactions include:
- 33/ISR/NV: Analyze unique and valuable contributions to reflect the real market value in related-party transactions.
- 34/ISR/NV: Prevent result manipulation by modifying transactions outside the interquartile range.
- 44/ISR/NV: Reject deductions for services not proven as effectively rendered.
Furthermore, certain risks may trigger Transfer Pricing Audits, such as:
- Failure to comply or late submission of transfer pricing obligations.
- An effective tax rate lower than the one published by the SAT, without proper justification.
- Use of reportable schemes or unreported aggressive tax practices.
- Unjustified tax losses.
If irregularities are detected, tax authorities may request detailed information and implement transfer pricing adjustments, leading to increased taxable income, reduction of deductions, or even the complete rejection of deductions.
Therefore, it is recommended to conduct a preventive tax diagnosis to identify potential risk areas and compile a defense file. This can help avoid penalties such as tax adjustments or deduction rejections during audits.
This plan reinforces the need for companies to adopt proactive measures to comply with current tax regulations through expert tax advisory services.
