Overview

• SAT detailed a 24 working‑day procedure that begins by blocking a suspect company’s billing from the first day of inspection.
• The plan contemplates mandatory pretrial detention for partners, shareholders and legal representatives of firms that issue false tax receipts, leveraging a recent constitutional change.
• The proposed CFF reform sets prison terms of two to nine years for issuing, selling, buying or acquiring invoices that back non‑existent or simulated operations.
• Authorities emphasize that the measures focus on a limited group of shell entities often tied to vacant or false addresses, while assuring compliant taxpayers they will not be targeted.
• Public lists under Articles 69 and 69‑B can be consulted on the SAT website and in the DOF to vet counterparties, and listed entities may challenge their status before the Tribunal Federal de Justicia Administrativa.