SAT steps up review of importers' registers and specific sector registers

Against this backdrop, timely compliance with applicable tax and customs obligations has become increasingly important, as has the periodic review of the suspension grounds established under Rule 1.3.3. of the General Foreign Trade Rules (RGCE), in order to mitigate operational risks and maintain the validity of the registrations required to carry out import activities. 

Key grounds for suspension

Based on our experience, the following are among the most common grounds for suspension:

• Not having a valid e.signature (e.firma).
• Failure to register or update contact details for Tax Mailbox purposes.
• Failure to file federal tax returns or non-compliance with tax obligations.
• Not carrying out foreign trade operations for a period exceeding twelve months.
• Failure to be located at the tax domicile or being deemed to have a non-existent tax domicile.
• Failure to maintain accounting records, registers, inventories, or controls required under tax and customs legislation.
• Having final tax liabilities or tax liabilities assessed by tax or customs authorities, under certain circumstances.
• Failure to maintain supporting documentation for foreign trade operations in accordance with applicable regulations.
• Failure to respond in a timely manner to requests for information or documentation issued by tax or customs authorities during audit or verification procedures, or responding incompletely.

The importance of timely action

Once the ground for suspension has been identified, it is important to analyse the specific circumstances of the case and comply with the applicable procedures and requirements for reinstatement, as these may vary depending on the relevant grounds. 

How can Forvis Mazars help? 

At Forvis Mazars, we have extensive experience assisting importers in identifying contingencies related to their registers, as well as in defining and implementing strategies for their reinstatement and regularisation before the relevant authorities. We remain at your disposal to support you with a preventive review of your current situation or in addressing any suspension that may affect your foreign trade operations.