On January 5, 2026, the SAT published new guidelines aimed at strengthening transparency, legal certainty and proportionality in tax audit procedures. Key measures include the publication of the 2026 Master Plan, limiting audits to one per taxpayer, requesting information through representative samples, and prioritizing audits involving high-risk tax practices.
In addition, the guidelines seek to unify audit criteria nationwide and shorten the timeframes for refunds of unduly paid taxes. As a result, the 2026 tax year will be particularly relevant for taxpayers, who will need to reinforce their supporting documentation and adopt preventive strategies to manage tax risks effectively.
Consult the full content of the Legal Briefing here.