In the context of increasing tax pressure and the need to strengthen public finances, the Tax Administration Service (SAT) has outlined strategic lines in the so-called Master Plan 2025, focused on increasing tax collection without creating or increasing new taxes. This plan includes specific measures aimed at combating tax evasion, smuggling and strengthening the tax culture.
Discretionary criteria and intensive auditing
In an interview for the newspaper El Norte, Dr. Gustavo Leal Cueva, partner at Leal Benavides y Cía, pointed out that the implementation of discretionary criteria by the SAT could generate uncertainty among taxpayers. This approach responds to the ambitious goal of reaching a collection of 5.3 trillion pesos by 2025, through more rigorous auditing actions and the intensive use of technological tools.
Among the most critical points of the Master Plan 2025 is the toughening of sanctions for incorrect practices related to:
Value Added Tax (VAT) declaration.
The Special Tax on Production and Services (Impuesto Especial Sobre Producción y Servicios, IEPS).
Activities related to smuggling.
Materiality of services and deductibility
A relevant aspect that generates concern is the criterion recently made official by the SAT regarding the materiality of services. This criterion establishes that, in order for an expense to be deductible, the taxpayer must demonstrate in a robust manner that the service was actually rendered. Although this practice was already common, its formalization as an institutional criterion increases the fiscal rigor and raises the evidentiary standard for taxpayers.
This change, together with the failure to update the maximum deductible amounts provided for in the Income Tax Law (ISR) since 2002, has significantly eroded tax benefits. According to Fiscalia's analysis, the cumulative impact represents a real reduction of more than 100% in the amounts to be deducted.
SAT Technology Strategies
The 2025 Master Plan prioritizes the use of advanced technology to identify irregularities and optimize auditing processes. This includes:
Massive data cross-checking: real-time analysis of information to identify tax inconsistencies.
Automation of processes: improvement in the detection of simulated operations and non-compliant taxpayers.
Digital platforms: promotion of tools to foster greater transparency in tax operations.
Impact on taxpayers
The combination of these strategies and discretionary criteria may imply significant challenges for individuals and corporations, who will face a greater administrative burden to comply with tax obligations. In addition, an increase in tax litigation is expected due to the strict interpretation of the provisions.
Recommendations for taxpayers
Against this backdrop, it is crucial that taxpayers adopt the following measures:
Periodic internal audits: ensure correct documentation of operations and their materiality.
Continuous fiscal updating: keep informed about SAT criteria and regulatory changes.
Specialized advisory services: having tax experts to help interpret and comply with the provisions rigorously.
Final comments
SAT's Master Plan 2025 reflects an intensive and technologically advanced tax approach aimed at maximizing tax collection in a complex economic environment; However, discretionary criteria and the formalization of new tax practices represent a significant challenge for taxpayers, who will need to strengthen their compliance processes to avoid penalties and legal controversies.
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