JANUARY 2026

The tax discrepancy occurs when There is a difference between income that a taxpayer declared before the SAT and the information that the authority obtains by data crossing (bank deposits, credit card transactions, etc.). The SAT has extensive oversight powers and automated tools to detect these differences in natural persons; Such detections may lead to invitations to clarify or regularize the situation or direct audits..

Tax discrepancies can arise simply from strict application of the law: In the nature of many operations there is a bank deposit which does not necessarily coincide with the taxed income what should be taxed, for example when it comes to loans, capital repayments, donations, exempt sales or movements between own accounts; when crossing information, the SAT detects the financial flow (the deposit) and compares it with what was declared, which may generate a technical difference although, from a tax point of view, part of these amounts are not subject to tax.

The problem is not having a tax discrepancy, but not being able to explain or document its origin.

This is the relevant extract from a “Invitation to verify or correct your tax situation” that the SAT directed to a taxpayer; The document was received in January 2026 and constitutes a real example of the way in which the authority communicates a possible tax discrepancy between the declared income and the bank deposits reported in their information crosses.

“Consultation of the “Declaration and Payment Services” system (referenced payment), It was learned that the taxpayer XXXX, presented normal annual return for the year 2024 on the 20th day of April 2025 with operation number: XXXX, where I manifest total cumulative income in the amount of XXXX, Likewise, it was known that due to the exercise 2024, received deposits in the amount of XXXX into its bank accounts, these being greater than the declared income“.

“In the same way, It is made known to you that, with voluntary compliance of tax provisions could avoid unnecessary acts of annoyance“.

“It is not omitted to point out that in accordance with the article 33, fraction IV, second paragraph, of the Federal Tax Code, The sending of this document is not considered the beginning of verification powers.”

The S.A.T., through automated crossings of the “Declaration and Payment Services” system and bank information obtained, detected that deposits in taxpayer accounts during 2024 exceed the income he declared in his annual return filed in April 2025. The authority offers a window for voluntary compliance in order to avoid “acts of nuisance”, and clarifies that sending the invitation is not equivalent to the formal initiation of verification powers; Nevertheless, The tone is preventive and seeks for the taxpayer to regularize their situation before the review escalates..

Although the aforementioned invitation does not formally initiate an audit, Its content reveals that The SAT has already identified a possible tax discrepancy and is inviting regularization. This implies that the authority has sufficient information to request clarifications or, in your case, initiate procedures if the invitation is not heeded. The detection of the discrepancy can come not only from bank deposits but also from cross-checking credit card account statements., including AMEX, Therefore, the scope of the tax authority is broad and requires an orderly and documented response..

The invitation, as indicated, was received in January 2026. For this reason, It is not advisable to wait for a similar invitation from the tax authority.; it is preferable to start documenting and classifying bank deposits. In this order of ideas, Our preventive recommendations are the following:

• Identify deposits by year. Review and list all bank deposits corresponding to the years 2023, 2024 Y 2025, indicating date, amount and receiving account.
• Classify deposits of tax origin. Indicate those that have already been accumulated in the declarations: wages, fee, income from business activity, dividends, bank interest, alienation of movable and/or real estate property, sale of shares on the stock market.
• Classify extra tax deposits. Identify movements that do not constitute taxable income but that may require expressing them in the annual return as informative data: donations, loans, house for sale, withdrawal and indemnities or other payments

It is also necessary to identify operations that do not require reporting in the annual declaration.: transfers between spouses, capital repayments of companies in which there is a shareholding

• Classify undeclared tax deposits. Identify movements that due to the circumstance that occurred were not included in the annual declaration and that give rise to the spontaneous correction of said omission.
• Document each deposit. Whether it is any of the deposits mentioned, Support must be gathered to prove the nature of each movement: contracts, loan letters, scriptures, sales receipts, donation receipts, invoices received, account statements, and “key” executive. further, assess in each case whether it is necessary to obtain the true date of the documents.
• Organize electronic file by year. Create a file per exercise that contains: annual and provisional declarations, account statements, contracts, notarial documents and invoices related to relevant acquisitions (vehicles, estate), all properly indexed.
• Evaluate corrections or clarifications. Based on classification and documentation, determine if appropriate: submit supplementary statements; prepare missing contracts; obtain the true date of the documents; or request from third parties the necessary documentation to justify the income received

Summary and conclusion

It's not the same identify a tax discrepancy that not being able to justify it: The exposure of a difference without documentary support is what really puts the taxpayer at risk. For this reason, the best defense upon an invitation from the SAT is to have organized documentation that serves to justify, deposit by deposit, the origin of the amounts detected

DFK MEXICO – FISCAL COMMITTEE