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Tax Law

Tax defense, planning, and compliance before federal, state, and municipal authorities

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The Tax practice of R&A Asociados offers comprehensive solutions in tax matters that combine legal defense, planning, and regulatory compliance. We assist companies and individuals at every stage of their relationship with the tax authorities: from a preventive review of their obligations to handling audits, negotiating tax assessments (créditos fiscales) and, where necessary, litigation before the TFJA (Federal Court of Administrative Justice) and amparo proceedings (Mexico's constitutional protection suit).

Our approach seeks to protect the taxpayer's interests and optimize their tax position before federal, state, and municipal authorities, always within the legal framework. We serve companies and individuals who need certainty in their transactions, whether to prevent tax contingencies, recover refundable balances, or respond to an act of authority (a government action) with a technical, timely, and properly documented strategy.

Services

What we do in this practice area.

01

Tax defense and litigation

Representation of taxpayers at the various levels of challenge against acts of the tax authorities.

  • Administrative appeals (recursos de revocación, inconformidad, and apelación)
  • Administrative litigation before the TFJA
  • Annulment actions (juicios de nulidad) against tax assessments, fines, and acts of authority
  • Direct and indirect amparo proceedings in tax matters
  • Defense against attachments (asset seizures), precautionary freezes of assets and bank accounts (aseguramientos), and administrative tax collection proceedings
02

Proceedings before tax authorities

Support throughout the exercise of audit powers, from the first request for information to the close of the audit.

  • Handling of audits, desk audits, and on-site audits (visitas domiciliarias)
  • Review of and response to letters of findings (oficios de observaciones) and tax determinations
  • Submission of evidence and appearances before the SAT (Tax Administration Service, Mexico's federal tax authority) or SEFIPLAN (Quintana Roo Ministry of Finance and Planning)
  • Negotiation and follow-up of tax assessments and payment arrangements
03

Refunds and offsets

Recovery of refundable balances and defense of the taxpayer when the authorities deny or delay them.

  • Processing and litigation of value-added tax (VAT, IVA), income tax (ISR), and other tax refunds
  • Filing of offsets and refundable balance claims
  • Representation before Prodecon (Mexico's Taxpayer Ombudsman) in mediation or tax complaint proceedings
04

Tax planning and compliance

Preventive strategies and fulfillment of tax obligations, always within the legal framework.

  • Design of preventive tax strategies within the legal framework
  • Analysis of the optimal tax regime for companies and individuals
  • Compliance with formal and substantive obligations: statutory tax audit report (dictamen fiscal), tax returns, CFDI (electronic tax invoices), and electronic accounting
  • Advice on transfer pricing and transactions with related parties
05

State and municipal tax audits

Responding to and challenging assessments and requests from state and municipal revenue authorities.

  • Response to requests from SEFIPLAN and from municipal treasuries and revenue offices
  • Defense regarding local taxes, such as the state schedular income tax (impuesto Cedular) and the state payroll tax (impuesto sobre Nómina)
  • Challenges to fines, closure orders, and determinations by local authorities
06

Strategic and preventive advisory

Early assessment of tax risks and technical opinions that support significant transactions and decisions.

  • Internal tax audits and compliance reviews
  • Tax risk assessment in corporate and real estate transactions
  • Tax opinions and compliance reports for third parties or authorities
  • Advice on international taxation and treaties for the avoidance of double taxation (tax treaties)

Services are provided in accordance with applicable law and the analysis of each case.

Who it is for

Who we serve in this practice area.

  • Companies and business groups facing audits, desk audits, or tax assessments from the SAT
  • Individuals with business or professional activities who need to determine their tax regime and meet their obligations
  • Taxpayers with VAT or income tax refundable balances pending refund or offset
  • Investors and developers with real estate or corporate transactions in the Riviera Maya who need to assess their tax impact
  • Groups with international operations or related parties that need advice on transfer pricing and double taxation

If your situation is not listed here, or the contact form can tell you which practice area applies.

Frequently asked questions

Common questions about this practice area.

What should I do if I have received a notice or a formal request from the SAT?

A formal request (requerimiento), a letter of findings, or the start of an on-site audit carries legal deadlines for a response, and the way it is handled from the outset affects how the proceeding unfolds. It is advisable not to ignore it, to keep the document and its proof of service, and to review with a specialist what is being requested and what documentation supports your position. If you would like us to review your case, we will be glad to schedule a consultation.

Can I challenge a tax assessment or a fine that I consider unfounded?

Mexican law provides various means of defense against acts of the tax authorities, such as the appeal for revocation (recurso de revocación), administrative litigation before the TFJA, and amparo proceedings, each with its own requirements and deadlines, which are generally counted in business days from service of notice. Determining whether an act can be challenged and which avenue is appropriate requires reviewing the document and your particular situation. We invite you to schedule a consultation to analyze the available alternatives.

Can you help me recover a VAT or income tax refundable balance?

The firm handles refund and offset requests for refundable balances and, when the authorities deny them, partially reject them, or fail to rule in time, also takes on the corresponding defense, including the involvement of Prodecon in complaint or mediation proceedings. Each case requires a review of the documentation that supports the balance. We will be glad to schedule a consultation to assess your situation.

These answers are for guidance only; each case requires individual analysis.

Publications

Publications in this practice area.

See all 2 publications in this practice area →

Consult with us on Tax matters.

Tell us about your situation and we will explain the next steps. We are available Monday through Saturday, 9:00 a.m. to 6:00 p.m., in Spanish, English, and French.

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