Short answer
A tax lawyer defends the company when the SAT or another tax authority audits it, issues an assessment or freezes its accounts. SNZ Legal Group assists companies in Guadalajara and Jalisco with audits, tax assessments, denied refunds and lawsuits before the Federal Administrative Justice Court (TFJA), working alongside the company's accountant.
How we help
- Responding to SAT reviews, invitation letters and audits.
- Revocation appeals and lawsuits before the TFJA.
- Defence against attachments and frozen accounts.
- Denied refunds of favourable balances.
- Restriction or cancellation of digital seal certificates (CSD).
- Tax amparo and conclusive agreements before PRODECON.
Means of defence
| Remedy | Before | General term |
|---|---|---|
| Revocation appeal | SAT | 30 business days (CFF 121) |
| Administrative lawsuit | TFJA | 30 business days (LFPCA 13, 74) |
| Summary lawsuit | TFJA, resolutions up to 30 times the annual UMA | LFPCA 58-2 |
| Amparo | District Court | 15 days, as a general rule (Ley de Amparo art. 17) |
| Complaint or conclusive agreement | PRODECON | During the audit |
Substance of transactions (materialidad)
The SAT often challenges deductions by questioning whether a transaction really happened. Proving it takes contracts, deliverables, emails, logs, photographs, bank transfers and evidence that the supplier had staff and assets. A CFDI invoice alone is not enough. Keeping that documentation from day one is the basis of a good defence.
Common mistakes
- Ignoring the Buzón Tributario.
- Answering an audit without reviewing what is delivered.
- Letting the 30-day period expire.
- Not securing the tax interest and suffering an attachment.
Frequently asked questions
What should we do if we received an assessment?
Note the notification date and seek advice immediately. See our guide on SAT tax assessments.
Can the SAT review prior years?
Generally, the authority's power to determine omitted taxes and impose penalties lapses after five years, counted as set out in CFF art. 67; in certain cases the period can be longer.
Do you keep the books?
No. We handle the legal defence in coordination with your accountant.
What is a carta invitación?
A notice from the SAT about possible discrepancies. It is not an assessment, but it should be answered carefully.
Related: SAT tax assessment guide · AML compliance · all guides · versión en español