L.C. Y L.D. Miguel Ángel García Piña
International Tax Associate en QCG Transfer Pricing Practice S.C.
On January 22, 2024, the Tax Administration Service (SAT) unveiled the 2024 Master Plan, outlining the strategies it will implement to meet this year’s revenue collection goals. The plan highlights improvements in taxpayer services, revenue collection, and tax auditing processes.
Notably, SAT will leverage Artificial Intelligence to enhance tax auditing procedures. Tax authorities have announced the application of graph analytics and machine learning models during the planning and programming stages of audits. These technologies will help identify and classify high-risk taxpayers or those using aggressive tax avoidance and evasion schemes. Additionally, SAT will analyze the consistency of invoiced transactions.
Tax auditing efforts will primarily focus on 18 sectors: automotive, alcoholic beverages and tobacco, wholesale and retail trade, construction, electronics, entertainment and shows, pharmaceuticals, hydrocarbons, hospitality and accommodation, logistics and transportation, metallurgy, parcel and courier services, technology platforms, advertising, insurance and financial services, real estate services, private education services, and private healthcare services.
Furthermore, authorities have outlined the key concepts and practices that will be subject to auditing, including corporate restructurings, tax effects of spin-offs, mergers and international restructurings, sales of shares and other intangibles, tax losses, preferential tax regimes, financing, debt capitalization, misuse of treaty benefits, among others.
As can be observed, SAT will increasingly rely on technological tools to identify and audit taxpayers with greater accuracy using its risk models. Many of the targeted transactions involve multiple companies within the same corporate group, making it crucial to pay special attention to transactions with related parties and compliance with transfer pricing regulations. Failure to comply could be flagged as a risk indicator, potentially triggering an audit by tax authorities.
The full 2024 Master Tax Auditing Plan is available at the following link.
