The use of Artificial Intelligence in the SAT 2024 Master Plan

B.Acy. and LL.B. Miguel Ángel García Piña

International Tax Associate at QCG Transfer Pricing Practice S.C.

On January 22, 2024, the Tax Administration Service (SAT) announced the Master Plan 2024, through which it informs the strategies it will implement to achieve its revenue objectives for this year. It states that it will improve its taxpayer service processes, collection, and auditing.

It is worth noting that the SAT will make use of Artificial Intelligence to enhance its auditing processes. The tax authorities have revealed that they will be applying graph analytics and machine learning models in the planning and scheduling stage of audits. The purpose is to detect and classify high-risk taxpayers or those with aggressive tax avoidance and evasion schemes. They will also analyze the coherence of invoiced concepts.

The auditing actions will primarily focus on 18 sectors: automotive, alcoholic beverages and tobacco, wholesale and retail trade, construction, electronics, entertainment and shows, pharmaceuticals, hydrocarbons, hospitality and accommodation, logistics and transportation, metallurgical, parcels and courier services, technology platforms, advertising, insurance and financial services, real estate services, private education services, and private healthcare services.

Additionally, they have pointed out that the main concepts and behaviors that will be subject to auditing, among which stand out include: corporate restructurings, tax effects in splits, mergers, and international restructurings, transfer of shares and other intangible assets, tax losses, preferential tax regimes, financing, capitalization of liabilities, misuse of treaty benefits, among others.

As can be seen, the SAT will increase the use of technological tools to identify and audit taxpayers more accurately based on their risk models. Many of the concepts to be reviewed involve operations among several companies within the same group, so special attention must be paid to transactions with related parties and compliance with the obligations of the transfer pricing regime. Failure to comply with these obligations may be a risk indicator that triggers an action by the tax authorities.

The complete Master Plan for Auditing 2024 is available at the following link.