Auditing Large Taxpayers: Mexico’s SAT Boosts Revenue Without Raising Taxes
Revenue from audits of large companies has surged since 2020 and has become a key pillar for sustaining tax receipts without a fiscal overhaul.
The strategy of intensive enforcement targeting large taxpayers has solidified as one of the Mexican federal government’s main revenue levers. According to figures from the Ministry of Finance and Public Credit (SHCP), resources collected through enforcement actions on companies with annual revenues above 1.5 billion pesos rose from 165.575 billion pesos in 2020 to 349.970 billion in 2025—an increase that, in practical terms, doubled this category’s contribution to public coffers.
The number matters not only because of its size, but because of what it reveals about Mexico’s revenue model in recent years: prioritizing the fight against tax evasion and avoidance—under the principle of “zero forgiveness”—rather than pursuing a sweeping tax reform. In an environment where social spending, pensions, and infrastructure projects put pressure on the budget, the Finance Ministry has sought to strengthen tax revenue through tighter oversight, litigation, and audits, especially of taxpayers with the greatest administrative and financial capacity.
In 2025, the amount collected through reviews, audits, information requests, on-site inspections, and “deep monitoring” schemes was equivalent to roughly 12% of all income tax (ISR) collected that year, according to the same official figures. That share shows how enforcement on large companies has shifted from a supplemental component to a structural source of revenue.
The policy continues under President Claudia Sheinbaum’s administration, with added emphasis on data analytics, digitization, and automated tools to select cases, cross-check information, and profile risks. The SAT has argued that its technological capacity enables more targeted audits, reducing error and increasing the likelihood of successful collection.
Greater efficiency, but also more controversy: the cost of litigation
Performance indicators reported by the Finance Ministry suggest improved enforcement effectiveness. Between 2020 and 2025, the average amount collected per enforcement action involving large taxpayers increased from 253 million to 285 million pesos, while the share of in-depth reviews that ended with collections above 100,000 pesos rose from 69% to 75%. Still, higher amounts and stronger pressure have also intensified administrative and court disputes. For companies, the environment implies higher compliance costs, accounting provisions, and in some cases prolonged litigation; for the government, the challenge is securing collections that are sustainable and defensible without undermining the regulatory certainty private investment typically demands.
In recent years, the list of large taxpayers subject to enforcement has included heavyweight corporate groups in the Mexican economy, including Grupo Elektra and TV Azteca, along with firms with significant footprints in retail, telecommunications, beverages, banking, and manufacturing. The focus is deliberate: the tax authority is looking to close revenue gaps where complex deduction structures, reorganizations, transfer pricing, or mismatches between reported income and observable cash flows tend to concentrate.
For 2026, the tax authority expects to keep the pace of reviews at around 1,200 large taxpayers, consistent with the idea that the biggest upside in collection can come more from higher compliance than from creating new taxes. This approach is also supported by the growing amount of information generated by digital tax invoices, payment platforms, and increased banking penetration, which make transactions easier to trace.
The backdrop is an economy with moderate growth, high sensitivity to the U.S. cycle, and domestic pressures from the financial cost of debt and spending needs. In that context, enforcement on large companies serves as a revenue “shock absorber”: it can improve intake without changing broad tax rates, but it also increases reliance on extraordinary collections and on administrative results that are not always linear.
Looking ahead, the challenge for the SAT and the SHCP will be to balance strict revenue enforcement with clear rules and streamlined processes, so that stronger revenue does not translate into uncertainty for investment. The signal is clear: without tax reform, the strategy will continue to rest on administrative efficiency, technology, and an active audit policy aimed at the largest taxpayers.
In perspective, the rebound in enforcement-driven revenue points to a more intensive tax administration with better tools, but its sustainability will depend on collections being recurring, transparent, and compatible with a predictable environment for economic activity.
