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Tax disputes for companies · Guadalajara

Tax disputes with the SAT, from Guadalajara

SAT audits, tax assessments, denied refunds and federal tax court litigation, coordinated with your company's accountant.

Reviewed by the SNZ legal team · Published October 29, 2026 · Zapopan, Jalisco

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Tax forms and a pen on a desk, tax lawyer in Guadalajara

Short answer

A tax lawyer defends the company when the SAT or another tax authority audits it, issues an assessment or freezes its accounts. SNZ Legal Group assists companies in Guadalajara and Jalisco with audits, tax assessments, denied refunds and lawsuits before the Federal Administrative Justice Court (TFJA), working alongside the company's accountant.

How we help

  • Responding to SAT reviews, invitation letters and audits.
  • Revocation appeals and lawsuits before the TFJA.
  • Defence against attachments and frozen accounts.
  • Denied refunds of favourable balances.
  • Restriction or cancellation of digital seal certificates (CSD).
  • Tax amparo and conclusive agreements before PRODECON.

Means of defence

RemedyBeforeGeneral term
Revocation appealSAT30 business days (CFF 121)
Administrative lawsuitTFJA30 business days (LFPCA 13, 74)
Summary lawsuitTFJA, resolutions up to 30 times the annual UMALFPCA 58-2
AmparoDistrict Court15 days, as a general rule (Ley de Amparo art. 17)
Complaint or conclusive agreementPRODECONDuring the audit

Substance of transactions (materialidad)

The SAT often challenges deductions by questioning whether a transaction really happened. Proving it takes contracts, deliverables, emails, logs, photographs, bank transfers and evidence that the supplier had staff and assets. A CFDI invoice alone is not enough. Keeping that documentation from day one is the basis of a good defence.

Common mistakes

  • Ignoring the Buzón Tributario.
  • Answering an audit without reviewing what is delivered.
  • Letting the 30-day period expire.
  • Not securing the tax interest and suffering an attachment.

Frequently asked questions

What should we do if we received an assessment?

Note the notification date and seek advice immediately. See our guide on SAT tax assessments.

Can the SAT review prior years?

Generally, the authority's power to determine omitted taxes and impose penalties lapses after five years, counted as set out in CFF art. 67; in certain cases the period can be longer.

Do you keep the books?

No. We handle the legal defence in coordination with your accountant.

What is a carta invitación?

A notice from the SAT about possible discrepancies. It is not an assessment, but it should be answered carefully.

Related: SAT tax assessment guide · AML compliance · all guides · versión en español

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What happens next

1 · Review
A lawyer at the firm reviews your information and may ask for a sample of documents.
2 · Written proposal
Scope, approach per account or matter, reporting format and responsible lawyer.
3 · Vendor onboarding
We provide the documents your procurement or compliance team requires.