The SAT may take into account information other than the revised fiscal year

The Financial Law of the Federation (CFF), that facts known to the tax authorities in the following manner may act as a catalyst for the decisions of the Ministry of Finance, and any other authority or decentralized body competent in matters of federal contributions [CFF 63]:

  • Mark the exercise of its powers of verification.
  • They appear in files, documents, or databases that they hold, have access to, or in their possession.
  • Those provided by other authorities.

And therefore, The court found that the tax authorities They can motivate their decisions with facts that they know through the listed media, without noting any condition regarding the date on which the facts to be made took place, or regarding the reasons for exercising a review.

This was repeated in the first section of the upper chamber of the House of Representatives Federal Court of Administrative Justice (TFJA) When resolving a controversial administrative trial. The thesis is part of the antecedents of the upper room.

You can review the TFJA thesis Here / Pages: 421 to 423 / Search criteria: Federal Tax Law / Key: VIII-P-1aS-790 / Publication date: April 26, 2021.


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