La Silla Rota: Tax Litigation: SAT Wins Fewer Cases but Collects 12% More

As of June 2026, Mexico's Tax Administration Service (SAT) had won 4,417 final rulings compared with 4,566 in the same period of 2025. Despite 149 fewer cases, revenue collected through this channel grew 12% year over year to 115.685 billion pesos versus 102.685 billion a year earlier, according to data from the SAT and the Ministry of Finance.

In an interview with La Silla Rota, Baker Tilly Mexico Tax Partner José Luis Elizondo said the result "may be due to several factors" and explained which ones weigh the most.

The factors behind the increase

The first is the size of the cases. "One of them may be that the rulings won were clearly for larger amounts," he said. Once a ruling becomes final, the tax assessment can be collected, so revenue can rise even if the number of cases won falls.

The second is the surcharge rate in force, which rose from 1.47% to 2.07% per month starting in 2026. "There is an increase; we have had this new surcharge rate for nine months," the specialist noted, which raises the amount of assessments that can now be collected.

On top of that is a stronger defense by the authority thanks to staff training. According to Elizondo, "it is a fact that the SAT makes fewer and fewer mistakes," with fewer procedural defects and better-targeted audits.

Disputes lasting up to three and a half years

Elizondo described the three stages of a regular tax dispute. The first is the administrative appeal (recurso de revocación) before the SAT's legal area, which can take eight months to a year. The second is the administrative lawsuit before the Federal Court of Administrative Justice, which takes one to one and a half years on average.

The third stage is decided by a collegiate circuit court and takes about one more year. Altogether, a dispute can last around three and a half years or longer if other appeals are filed.

At Baker Tilly, we help companies review their tax assessments and build their defense strategy before the authority, from administrative appeals to judicial proceedings.

Article originally published in La Silla Rota, by José Manuel Arteaga.