Practice areas · Tax
The SAT has served notice. Now the clock counts.
We design the defense, file it and sustain it through to the ruling.
Administrative appeal before the SAT · Annulment proceedings before the Federal Tax Court · Clarification briefs and rebuttal of presumptions · Complaints before PRODECON when the conciliatory route works better
Who needs it
Three concrete situations
01
A tax assessment was issued against you and the challenge period is running.
02
You are under a desk audit or an on-site inspection and do not know what to hand over.
03
You were listed under article 69-B and your clients have started asking questions.
What it includes
Scope of service
Administrative appeal before the SAT
Annulment proceedings before the Federal Tax Court
Clarification briefs and rebuttal of presumptions
Complaints before PRODECON when the conciliatory route works better
From day one you know what can be annulled, what can be reduced and what is better negotiated.
How it is delivered
From first contact to resolution
01
Reading the file and the deadline
We review the notification, the audit record and the working papers before choosing the route.
02
Choice of route and filing
Administrative appeal, annulment proceedings or PRODECON complaint, depending on the amount and the timing.
03
Sustaining it through to the ruling
Evidence, arguments and, if the ruling is unfavorable, amparo at the corresponding instance.
Questions
What clients ask first
How long do I have to challenge a tax assessment?
The administrative appeal is filed within thirty business days of notification, and the annulment claim before the Federal Tax Court within the same term. The period runs from when the notification takes effect, not from when you received it.
Administrative appeal or straight to court?
It depends on the defect in the ruling and the evidence available. The appeal allows evidence that was not submitted during the audit; going to court avoids losing time when the defect is substantive. We decide with the file on the table.
Can collection be stopped while the matter is defended?
Yes, by securing the tax interest under the terms of the Federal Tax Code or by requesting a stay in the proceedings. We explain the cost of each option before you decide.
Next step
Does your matter involve tax defense? Tell us.
We work Monday to Friday, 9:00 to 16:00. Write or call +52 55 6791 2014.