On January 29, 2023, the Tax Administration Service published the Taxation and Collection Master Plan for the fiscal year 2023. The Plan contemplates a coordination strategy between the General Collection, Large Taxpayers, Federal Tax Audit and Foreign Trade Audit Departments.

The audit strategy is divided into the following aspects:

• Authority Management: Will seek to accompany taxpayers for voluntary compliance, optimize the process of recovering tax credits, regularize taxpayers who are in default or who present differences in their obligations, and coordinate with federal entities.
• Control actions: Combat evasion by "invoice" and "nominee" companies and smuggling in warehouses. The analysis and programming of atypical income and expense items will be strengthened, as well as foreign trade reviews. The effective rates for fiscal years 2020 and 2021 were published.
• Economic sectors to be reviewed: Steel, food, automotive, beverages and tobacco, commerce, construction, electronics, energy, entertainment, pharmaceuticals, mining, real estate services, financial system, stock holdings, telecommunications, and tourism/hospitality.
• Concepts and conducts to be reviewed: Undue application of credit balances, hydrocarbon supply chain, excise tax credits, exempt pensions in payroll and simulation of rendering specialized services, refunds, 0% non-object and temporary import rate, undervaluation in foreign trade operations and undue use of treaties, verification of compliance with VAT and excise tax certifications, mining rights, corporate restructurings and tax effects in spin-offs and mergers, partners and shareholders, tax losses, preferential tax regimes, financing, capitalization of liabilities and distribution of profits, foreign payments and international restructurings and trusts.

We thank you for your confidence in the Firm and remain at your disposal should you require any additional information related to this note.