La Silla Rota: SAT raises fine collection 103% and cuts taxpayer refunds

In the first half of the year, Mexico's Tax Administration Service (SAT) increased revenue from fines and reduced the refunds issued to taxpayers.

According to information from the Ministry of Finance and Public Credit (SHCP), tax fines on taxpayers rose 103.28% in one year. Between January and June 2025, revenue from fines totaled 12,215 million pesos, while in the first half of 2026 the figure climbed to 24,813 million pesos.

José Luis Elizondo, Legal Associate at Baker Tilly, noted that in recent years the SAT has adopted a series of mechanisms that have enabled greater technology-driven enforcement. In an interview with La Silla Rota, he stated that the authority's efforts to scrutinize taxpayers are here to stay, so taxpayers must exercise greater control over their activities in order to correct them where necessary.

The categories in which the tax authority increased collection are: violations of foreign trade provisions, tax correction, fines imposed by state governments, and failure to comply with or late responses to RFC requirements and obligation controls.

Fewer VAT and IEPS refunds

Adding to this, refunds issued by the SAT fell 12.26% in one year. In the first half of 2025 refunds totaled 490,200 million pesos, while in the same period of 2026 they reached 430,092 million pesos.

Value Added Tax (VAT) refunds contracted 15.41%: between January and June 2025 they amounted to 433,563 million pesos, compared with 366,741 million in the same period of 2026.

Refunds of the Special Tax on Production and Services (IEPS) fell 17.67% year over year, from 5,625 million pesos to 4,631 million. By contrast, Income Tax (ISR) refunds rose 19.32%: the authority had issued 48,609 million pesos and in 2026 recorded 58,003 million.

Tighter controls

Elizondo highlighted that over recent years the SAT has gained more technological tools through amendments to the Federal Tax Code, such as the cancellation of digital seals. He added that the authority has taken a more active stance in foreign trade reviews, where violations are highly significant and frequent, as they can start at 80,000 pesos per customs declaration.

"These are relatively simple aspects to audit with substantial penalties… it is an area that gives it relatively simple audits, in quotes, in the sense that it does not have to get into highly technical matters, with significant revenue," he said.

According to the authority's figures, fines related to foreign trade reached 2,986 million pesos in the first half of the year, compared with 1,291 million in the same period of 2025, an increase of 131.29%. Another relevant factor concerns tax corrections, which went from 10,363 million pesos in the first half of 2025 to 21,497 million in 2026, an annual increase of 107.43%.

Elizondo explained that if taxpayers realize they made an error in their tax position and proceed to self-correct before the authority has initiated its audit powers, this is in principle a voluntary action and there would be no violation.

"If the authority has already initiated its powers and the taxpayer proceeds with the correction once those powers have begun, there are reductions in the fine, and it will depend on when that correction is made, depending on the stage of the audit," he emphasized.

The expert considered that taxpayers should stay closely informed and work alongside advisors and professionals, accountants and tax attorneys, regarding tax changes.

"To the extent that we document operations in the present, let us remember that the authority generally has a five-year window to review us. So if I start documenting 2026 operations today and an audit arrives in 2030 for fiscal year 2026 and I have it documented, it will be easier for me to respond to all requirements than to start looking for documentation from years back," he explained.

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