SAT'S AUTHORITY TO CONDUCT DOMICILIARY VISITS USING TECHNOLOGY

In late January 2026, Mexico´s Supreme Court of Justice (SCJN), in ruling on Direct Appeal (Constitutional Protection Lawsuit) 5803/2025, confirmed the constitutionality in favor of the Tax Administration Service (SAT) of the amendments to Articles 42, 44, and 45 of the Federal Tax Code.

What does this ruling imply?

The tax authority now has constitutional backing to conduct domiciliary visits using technological tools, such as cameras and video cameras, in order to document its verification activities and strengthen the fight against tax evasion.

It is important to note that, contrary to certain misinformation circulated, this measure will not be applied across the board to all taxpayers but will be focused on specific cases of tax risk.

Main profiles subject to these visits in 2026:

• Fictitious Invoicing Companies (EFOS): Companies that report significant transactions, but whose tax address is an empty apartment or an abandoned warehouse. The tax authority may document the lack of infrastructure through video recording to legally demonstrate the absence of actual operations.

• Taxpayers with obvious “tax discrepancies”: Individuals whose expenses or purchases significantly exceed their reported income, which will allow SAT to gather visual evidence of unreported assets.

• Fictitious tax addresses (ghost offices) registered as residential addresses: Cases in which private residences are registered as business locations with no actual activity, with the aim of deducting expenses such as electricity, internet, and rent. If SAT does not detect any actual business activity, it may use cameras to verify that the address is strictly residential and will proceed to reject the deductions.

• Unlocated (invisible) taxpayers: Those who cannot be located at their tax address or who fail to comply with their reporting obligations through the “Buzón Tributario”, which may lead to more severe measures, as auditors will be sent to verify that they have disappeared, resulting in the immediate freezing of their bank accounts.

Given this new criterion, it is essential that taxpayers:

• Keep their tax information up-to-date and accurate.

• Ensure consistency between income, expenses, and assets.

• Verify that their tax address reflects actual business operations.

• Respond promptly to any communication from the tax authority.

At TP Legal, our specialized team is available to review your specific tax situation and provide proactive support in the event of a potential tax audit.

Contact us: contacto@tplegal.mx  •  www.tplegal.mx