SAT authority to freeze bank accounts for tax debts

The Mexican Tax Administration Service (SAT) has the authority to freeze bank accounts to collect enforceable tax credits or to guarantee debts under specific legal circumstances. According to the Federal Tax Code (CFF), this measure is not applied indiscriminately to all accounts of an individual or entity.

There are two primary procedures for such actions: the Administrative Execution Procedure (PAE), aimed at making enforceable tax credits effective, and precautionary seizures used during verification processes under Article 40-A of the CFF.

Account immobilization typically occurs when a taxpayer has unpaid tax debts that were not contested within legal timeframes, or when a final resolution is issued in favor of the SAT. Additionally, if a debt is subject to legal defense and the taxpayer fails to provide the required guarantees, the authority may order the freezing of bank deposits, insurance, or other investments for an amount equivalent to the updated debt and its accessories.