EL RECURSO DE REVISIÓN EN MATERIA FISCAL, ¿JUICIO ...
www.justiniano.com › revista_doctrina › IXOYE
Por ejemplo en materia de amparo, existen los recursos de revisión, queja y ... Este juicio se promueve ante el Tribunal Fiscal de la Federación a petición de la ... cuales procede el recurso: en contra de las resoluciones dictadas por las salas ... a petición de parte por la Segunda Sala de la Suprema Corte de Justicia de la ...

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Tax Mediation, Administrative and Judicial Appeals in Mexico
taxpayerrightsconference.com › abstracts-papers › tax-mediation-adm...
If that judgment is confirmed, it can be appealed to the Supreme Court of Justice as long as the tax conflict identified during the audit involves an aspect of constitutionality. The decisions of the Supreme Court cannot be challenged.

Tax review?

https://home.kpmg/us/en/home/insights/2019/12/tnf-mexico-tax...
Mexico: Tax reform for 2020; focus on international taxation, digital taxation, other items



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https://www.lexology.com/library/detail.aspx?g=718609da-59d5...
Enforcement

Compliance with tax laws

How does the tax authority verify compliance with the tax laws and ensure timely payment of taxes? What is the typical procedure for the tax authority to review a tax return and how long does the review last?

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Typically, a tax audit starts with the notification of an official letter containing the list of taxes that are to be reviewed and over which period. Usually, the tax authorities have a 12-month period to review the documentation provided by the taxpayers and issue an official letter including the observations that could result in a tax assessment (certain exemptions apply). After being notified of such official letter, taxpayers have a deadline of 20 working days to provide additional information.

If the documentation provided by the taxpayer is considered insufficient by the tax authorities, they have six additional months to issue the corresponding tax assessment.

A tax audit usually lasts one year (not taking into account the six-month term the tax authorities have to issue the corresponding tax assessment). However, the following exceptions exist:

audits initiated to financial institutions or business groups that consolidate for tax purposes can last 18 months;
audits in which the tax authority requests information from foreign tax authorities can last two years; and
audits related to transfer pricing issues or verification of the origin of goods can last two years.
Types of taxpayer

Are different types of taxpayers subjected to different reporting requirements? Can they be subjected to different types of review?

Yes, the Mexican tax laws provide several differentiated reporting obligations depending on the type of taxpayers (as a matter of fact, such reporting obligations frequently transcend to other subjects dissociated from the tax relationship).

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http://www.taxsummaries.pwc.com/ID/Mexico-Corporate-Tax-admi...
Tax audit process
In general terms, for taxpayers that elected to file a tax-compliance audit report, the tax audit (tax inspection) may start with a review of the audit report prepared by the independent CPA. At this point, the tax authorities may finish the audit if they are satisfied with the information provided by the CPA; otherwise, tax authorities may initiate a direct review on the taxpayer either at the tax authority's offices or at the taxpayer's facilities. Tax authorities may request several documents from the taxpayer and third parties that carried out transactions with the audited taxpayer.

Tax audits should be concluded within the following 12 months after the audit was initiated. The period to conclude tax audits for taxpayers that are either part of the financial system or consolidated for tax purposes is 18 months. In cases where the Mexican tax authorities request information to tax authorities from foreign jurisdictions, the period to conclude the audit is two years. The above periods might be suspended under certain circumstances (e.g. a judicial recourse or appeal initiated by the taxpayer against the tax authorities). Upon conclusion of the audit, the tax authorities should issue either a notification explaining tax underpayments observed during the audit process or a notification of conclusion if no issues remain open at the end of the inspection.

Finally, tax authorities should issue a notification of assessment within the six months after the conclusion of the tax audit. At this point, all underpayments claimed by the tax authorities become due.