The Tax Administration Service (SAT) offers the possibility of resolving queries related to the interpretation or application of tax provisions, whenever it concerns specific situations that have not yet been carried out.
This mechanism, regulated in Rule 2.1.45 of the Miscellaneous Tax Resolution 2025, allows taxpayers to obtain clarity on the tax treatment of certain future acts or transactions, avoiding errors and penalties.
How does this option work?
- Presentation of the consultation:
- The application must be made using the processing form 186/CFF “Online consultations and authorizations”, contained in Annex 1-A of the Miscellaneous Tax Resolution.
- The taxpayer must detail the specific situation that he wishes to consult and demonstrate that it has not yet been carried out.
- Validity of the response:
- The resolutions issued by the SAT are valid during the fiscal year in which they are issued and three additional months, provided that the applicable tax provisions do not change and the same subjects and legal assumptions are maintained.
- Limitations:
- The SAT is not obligated to apply the criteria issued in these resolutions to future cases or to publish extracts of the favorable resolutions.
What kind of queries can you make?
Permitted queries are those seeking to clarify the tax treatment of future acts or decisions. Some examples include:
- Investment strategies:
A company plans to purchase machinery and wants to confirm whether this transaction qualifies for an immediate deduction. - Corporate restructuring:
A company is considering splitting into two legal entities and is considering whether the transaction qualifies as a tax-neutral spin-off. - Specific operations:
A taxpayer plans to import goods and requests confirmation on the applicable VAT rate or a possible exemption. - Application of tax incentives:
A company that wants to hire people with disabilities consults the requirements to apply the corresponding tax incentive. - Tax credit:
Before making payments abroad, a company checks whether it will be able to credit the VAT related to these operations.
What topics are excluded?
Not all queries are accepted. Some topics that are outside this facility include:
- Transactions between related parties.
- Tax incentives for the northern or southern border region.
- Refunds, compensations or credits.
- Cases already subject to audit or with means of defense filed.
- Issues related to controlling beneficiaries, preferential tax regimes or international agreements.
Why take advantage of this option?
Making an inquiry to the SAT can be a powerful tool to plan your tax decisions with greater certainty. By knowing in advance how the tax provisions will apply in your case, you can reduce risks and optimize compliance with your tax obligations.
If you have questions about how to submit a query or need support in preparing it, TAX ID Mexico is here to help. Contact us and ensure that your tax decisions are clear and correct from the start.
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