Overview
- The Senate approved changes to the administrative procedure law, allowing the SAT to seek review of adverse rulings and curbing provisional suspensions so enforcement actions can continue during disputes.
- The measure advanced to the Chamber of Deputies for further debate, with opposition warning of disadvantages for taxpayers and entry into force slated for 2026 if finalized.
- SAT officials said the reforms focus on issuers of false invoices rather than compliant taxpayers, describing the actions as targeted and justified.
- The SAT rejected assertions of automatic preventive imprisonment and said the package does not create new powers to freeze bank accounts.
- The agency underscored that investigations must be substantiated and taxpayers’ hearing rights remain, while the reform modernizes procedures with digital filings and stricter deadlines, and allows fiscal interest to be guaranteed through instruments such as deposits, pledges, mortgages, credit letters, bonds, joint obligation or administrative embargo.