From a $269M MXN assessment to less than $9M. ZERO PENALTIES paid.
How a manufacturer under a three-year SAT audit reduced its exposure by 96.7% with Prodensa
CASE BACKGROUND
In 2022, before SAT formally requested action, Prodensa identified an opportunity to regularize the client’s foreign trade position and recommended proactively approaching the authority to address it.
Shortly afterward, SAT issued a first invitation letter covering three fiscal years. The client, supported by Prodensa, submitted information in response; however, the authority still had questions regarding the evidence provided and the treatment of the transactions under review.
Approximately six months later, a second invitation letter was issued. Additional information and supporting evidence were submitted, but the authority continued to seek further clarification.
In 2024, SAT opened a formal audit covering the same three fiscal years. At that stage, Prodensa coordinated the submission and review of reports, pedimentos and other supporting documentation to
demonstrate the proper return and legal status of temporarily imported raw materials and finished goods. The team also met directly with the authority to address questions related to previously submitted Annex 24 inventory-control reports.
When questions remained unresolved, Prodensa brought the matter before PRODECON, which served as an intermediary between the taxpayer and the authority. Through multiple working sessions, written submissions and responses to the parties involved, the team continued building the evidence required to substantiate the client’s position and move the case toward resolution.
The process ultimately resulted in a 100% reduction of penalties across the three fiscal years under review, along with surcharge reductions of up to 85%, significantly reducing the client’s total financial exposure.
The Specialized Audit Team
Combining experts from different specialties to create a highly effective solution for our client.
CHALLENGES
- Review spanning three fiscal years, including older records that were increasingly difficult to reconstruct.
- Annex 24 inventory-control information required detailed analysis and clarification to demonstrate the proper return of temporarily imported merchandise.
- Annex 30 presented additional compliance and evidentiary considerations that needed to be addressed.
- Multiple rounds of information requests required the team to continuously organize, validate and substantiate supporting documentation.
- High personnel turnover had affected continuity in internal controls and compliance processes.
- Documentation inherited from previous teams was incomplete and lacked a structured handover.
- Even after reports, pedimentos and supporting evidence were submitted, the authority continued to raise questions that required technical and legal clarification.
- The case ultimately required coordination among the client, Prodensa, SAT and PRODECON to reach a resolution.
The Prodensa Solution
Prodensa built the defense around one clear strategic objective: minimizing the financial impact, while mobilizing and coordinating the firm’s multidisciplinary expertise around that goal.
- Leadership
- Specialists
- Legal
- PRODECON
- Proactivity
- Deadlines
Leadership with authority-side experience.
The engagement was directed by a Prodensa executive with extensive experience navigating SAT procedures. That perspective helped define the strategy at each stage—from the initial regularization effort and invitation letters to the formal audit and eventual PRODECON process.
Annex 24 specialists answering the technical record.
Prodensa’s Annex 24 specialists analyzed the inventory-control reports and supporting records needed to demonstrate the proper return and legal status of temporarily imported merchandise. When the authority raised questions, the team reviewed the information in detail, clarified report outputs and provided additional evidence as required.
Legal grounds and controlled communication.
Prodensa’s legal team coordinated the formal responses, supporting arguments and communications with the authority. Throughout the process, the objective was to maintain a technically supported and constructive dialogue while protecting the client’s position.
Escalation to PRODECON
When questions remained after the formal audit responses and direct working sessions with SAT, Prodensa brought the matter before PRODECON as an intermediary between the taxpayer and the authority. This created a structured channel to present additional evidence, address outstanding questions and work toward an agreed resolution.
A legal representative who did not wait.
From the initial voluntary regularization effort through the audit and PRODECON process, Prodensa continuously tracked the case, coordinated the information requested from the client and aligned the technical and legal teams around each new requirement.
Operations executing under a hard deadline.
Once the resolution was reached, approximately 47 pedimentos had to be regularized within a 15-day window, including the December holiday period. Prodensa coordinated the operational work required to prepare, file and pay them before the applicable deadline.
RESULTS
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$260.2M MXN retained by the client. Instead of absorbing the full initial assessment, the company preserved the vast majority of the capital originally at risk.
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100% of penalties waived across the three fiscal years under review.
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Surcharges reduced by up to 85%.
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47 pedimentos regularized within the required 15-day period, completing the operational steps necessary to close the process.
Prodensa Tips
If your company receives an invitation letter or notice from SAT, how the issue is assessed and documented from the beginning can significantly affect what follows.
Our team’s recommendations:
- Act
- Analyze
- Respond
- Transparency
- Organization
- Escalate
- Coordinate
Act early, even before a formal request arrives
If your internal controls identify a potential compliance issue, evaluate the need for corrective action before it escalates. Proactive regularization can provide more options than waiting for a formal audit.
Analyze in precise detail what the authority is actually asking for.
Understand the scope, periods, transactions and evidence requested before you respond.
Answer exactly what was requested and support it with evidence.
A response should directly address the authority’s questions and be backed by documentation that can be reconciled with operational and customs records.
Maintain real Annex 24 control and inventory transparency.
Physical inventory, customs records and inventory-control systems should reconcile continuously, not only when an authority requests information.
Keep electronic files organized by transaction.
Reports, pedimentos and supporting documentation maintained during normal operations may become critical evidence years later.
Escalate strategically when necessary.
When technical evidence alone does not resolve the authority’s questions, evaluate the available legal and institutional mechanisms (including PRODECON) to determine the best path toward resolution.
Coordinate technical, operational, and legal teams.
Complex foreign trade audits rarely belong to a single discipline. Annex 24, customs documentation, legal strategy and communication with the authority need to work from the same set of facts.
SCHEDULE A MEETING WITH AN EXPERT
Prodensa has supported foreign manufacturers operating in Mexico for over 40 years, including IMMEX compliance, Annex 24 and Annex 30 control, and audit defense.
