Short answer
A crédito fiscal is an amount the SAT determines your company owes, usually tax plus inflation adjustment, surcharges and fines. You can pay it, request instalments, or challenge it. To challenge it you generally have 30 business days from the day notification takes effect to file a revocation appeal with the SAT (Código Fiscal de la Federación, CFF, art. 121) or a lawsuit before the Federal Administrative Justice Court (TFJA) (Ley Federal de Procedimiento Contencioso Administrativo, LFPCA, art. 13). To stop collection while you litigate, you normally must secure the tax interest (CFF art. 144).
Your options
- Pay, if the assessment is correct.
- Pay in instalments: up to 36 monthly instalments or deferral of up to 12 months, paying 20% of the total upfront (CFF art. 66).
- Revocation appeal (recurso de revocación) before the SAT, filed through the Buzón Tributario.
- Lawsuit (juicio contencioso administrativo) before the TFJA, online or on paper.
The right route depends on the grounds of the assessment and on the evidence your company has.
How the 30 days are counted
Deadlines set in days under the CFF exclude Saturdays, Sundays, statutory holidays and general vacation periods of the tax authorities (CFF art. 12). Before the TFJA, days are likewise counted as business days (LFPCA art. 74). Count carefully: once the period expires, the assessment becomes final and can no longer be disputed. The summary procedure (juicio sumario), available for resolutions not exceeding 30 times the annual UMA, also requires filing within the applicable period (LFPCA art. 58-2).
| Revocation appeal | TFJA lawsuit | |
|---|---|---|
| Before | The SAT | Federal Administrative Justice Court |
| Term | 30 business days (CFF 121) | 30 business days (LFPCA 13, 74) |
| Filing | Buzón Tributario | Online or traditional |
| Advantage | New evidence can be offered | Decided by an independent court |
| If lost | You can still go to the TFJA | Direct amparo may follow |
Securing the tax interest
Administrative acts are not enforced when the tax interest is secured in accordance with the law, and an assessment is not enforced until 30 days after its notification takes effect (CFF art. 144). Security may take the form of a deposit, a bond (fianza) or an administrative attachment, among others. Without it, the SAT may start the administrative enforcement procedure: attachment of accounts or assets and, eventually, auction.
What if notification was defective?
If the company alleges the resolution was not notified or was notified illegally, it can challenge the notification together with the resolution, stating in the lawsuit the date on which it learned of it (LFPCA art. 16). The court examines the notification first.
Documents to gather
- The assessment and the notification record.
- Tax returns and the accountant's working papers.
- CFDI invoices, contracts and evidence that the transactions were real.
- Bank statements.
- Records and official letters from the prior audit.
Common mistakes
- Counting calendar days instead of business days.
- Assuming an informal "clarification" stops the deadline.
- Not securing the tax interest and suffering an account freeze.
- Filing without evidence.
Frequently asked questions
Can the SAT freeze our bank accounts?
Yes, in certain cases, for example when the assessment is enforceable and has not been secured. There are legal means to request release, usually by offering security or showing the assessment is challenged and secured.
Appeal or lawsuit: which is better?
The revocation appeal is filed with the SAT itself and is optional; the lawsuit goes to an independent court (TFJA). The choice depends on the grounds and the evidence.
Can we request a conclusive agreement now?
No. The conclusive agreement (acuerdo conclusivo) before PRODECON is requested during the audit, before the assessment is issued.
What happens if we do nothing?
The assessment becomes final, keeps accruing inflation adjustments and surcharges, and the SAT may start the administrative enforcement procedure against assets and accounts.
Does the court charge fees?
The TFJA does not charge to file and, as a rule, there is no award of costs (LFPCA art. 6), except when the claim is notoriously dilatory. Professional fees and the cost of security still apply.
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