Blocked invoicing certificate (CSD)
The SAT restricted your digital seal certificate under article 17-H Bis and you cannot invoice. The clarification comes first; the amparo follows if the SAT stalls or refuses without proper grounds.
Your invoicing certificate is blocked, your account is frozen, an assessment landed, or you were published on the article 69-B list. Every day costs money. We draft and file your tax amparo for a flat MX$9,900, in any Mexican state.
Free opinion within 24 h · If another remedy fits better, we tell you
You do not need to be a large company. These are the SAT actions that most often end up in an amparo:
The SAT restricted your digital seal certificate under article 17-H Bis and you cannot invoice. The clarification comes first; the amparo follows if the SAT stalls or refuses without proper grounds.
Precautionary seizure or immobilisation through the administrative enforcement procedure. Here the suspension matters more than the judgment: without accounts, a business stops within days.
Assessments with defects in their legal grounds, their reasoning or the way they were served. Note that once an assessment becomes final, the 2025 reform narrowed your options considerably.
Published as a company invoicing simulated operations, or presumed to have received such invoices. The windows to rebut are 15 and 30 business days, and they do not extend.
VAT or income tax credits the SAT refuses, requests impossible evidence for, or simply never resolves. An annulment suit is sometimes the better route; we say which.
Field audit orders, desk reviews or electronic reviews with defects at origin: unfounded jurisdiction, exceeded time limits or disproportionate information requests.
Losing your e.firma locks you out of nearly every filing. It is a challengeable act in its own right and usually travels alongside a blocked certificate.
A negative opinion under article 32-D costs you government contracts and large clients. If the underlying reason is wrong or already cured and the SAT will not update it, it can be challenged.
Rules that affect you from the moment they take effect or from their first application to you. Quoted separately from MX$19,900, since the constitutional analysis is far more extensive.
What clients actually need is rarely a judgment a year from now. It is for the authority to stop causing damage tomorrow. That is the suspension of the challenged act, and in tax matters it follows its own rules:
| Challenged act | Suspension available? | Condition |
|---|---|---|
| Collection of a tax assessment | Yes, conditionally | Guarantee the tax interest: bond, deposit certificate, letter of credit or administrative lien |
| Assessment already final | Heavily restricted | The 2025 reform pushed challenges to later stages of the collection process |
| Blocked invoicing certificate | Yes | No tax guarantee required; the request is to let you invoice while the case runs |
| Account freeze ordered by the financial intelligence unit | No | Added to the grounds barring suspension on public-interest grounds |
| Audit in progress | Case by case | Stopping a whole audit is rare; specific requests can be narrowed |
The decree published on 16 October 2025, in force the following day, reshaped tax amparos. Three changes affect the strategy of any case filed today.
Final assessments. Challenges to assessments that have already become final were pushed to later stages of the collection procedure. Letting an assessment become final is now far more expensive than it used to be.
Guarantee for the suspension. For final assessments and for decisions on statute-of-limitations claims, the suspension requires a guarantee posted through a deposit certificate or a letter of credit.
Stricter legitimate interest. You must show a real injury, differentiated from the general public, and that annulling the act produces a certain rather than hypothetical benefit.
The practical translation for a taxpayer: acting early is worth more than ever. A problem handled at the clarification or administrative-appeal stage is cheap. The same problem, once the assessment is final, becomes expensive litigation with fewer tools.
Send us the official letter, the resolution or a screenshot from the Buzón Tributario. That tells us the challenged act, the responsible authority and the deadline you actually have.
We tell you whether it is an amparo or whether a clarification, an administrative appeal, an annulment suit or a PRODECON settlement comes first. If a guarantee is involved, you get the estimate. Free.
A single payment of MX$9,900. We send you the claim to review and sign with your electronic signature or by hand.
We file electronically before the competent District Court and update you on every ruling, on the suspension hearing and on the judgment.
A flat MX$9,900 with VAT included, roughly 500 US dollars, anywhere in Mexico. That covers the case review, drafting the claim, the request to suspend the challenged act, filing before the District Court and follow-up through to first-instance judgment. The only separate cost is the tax interest guarantee where the law requires one, and that money goes to a surety company or into a deposit — not to us.
Rarely. Article 17-H Bis of the Federal Tax Code gives you a clarification procedure to rebut the grounds for the restriction, and the SAT has 40 business days to resolve it. That route is usually faster and cheaper than litigation. An amparo becomes the right move when the SAT fails to resolve within the legal period, resolves against you without proper grounds or reasoning, or cancels the certificate outright. Message us the day it happens and we will tell you which scenario you are in.
Only if you obtain the suspension, and in tax matters the suspension comes with conditions. You must guarantee the tax interest before the authority, through a bond, a deposit certificate, a letter of credit or an administrative lien. On top of that, since the October 2025 reform, amparos against tax assessments that are already final were pushed to later stages of the collection process. Timing matters as much as the arguments.
It is the rule that you must first exhaust the ordinary remedies the law makes available before turning to an amparo. If an administrative appeal before the SAT or an annulment suit before the Federal Administrative Court was available and you skipped it, the judge dismisses without examining the merits. There are important exceptions, such as when the remedy is optional or when it imposes stricter requirements than an amparo for obtaining a stay. Working out whether your case falls into an exception is exactly what the free assessment does.
It depends on the stage. If you were just notified of the presumption, you have 15 business days to submit evidence rebutting it in the administrative phase, and that is where most cases are actually won. Once the definitive publication is out, the route is usually an annulment suit and, depending on the facts, an amparo. If you received invoices from a listed issuer, you have 30 business days to prove the transactions were real or to correct your tax position. These deadlines do not extend.
Yes. The amparo protects any person or legal entity in Mexican territory, including foreign nationals and foreign-owned Mexican companies. Nationality is irrelevant to standing. What matters is that the act of the authority affects you legally and that you meet the procedural requirements, including the stricter legitimate-interest standard introduced by the 2025 reform.
Sometimes, and sometimes another route is better. If the SAT deemed your refund application abandoned or denied it with a poorly reasoned decision, an annulment suit before the Federal Administrative Court usually allows a broader review of the evidence. If what you face is total silence or an unlawful information request that leaves you defenceless, an amparo can be the faster path. We tell you which before charging you.
No, and be sceptical of anyone who promises that. What we guarantee is the flat fee, the filing deadline, and an honest opinion before you pay on whether your case has a real chance or whether an administrative appeal, an annulment suit or a settlement through the taxpayer ombudsman suits you better.
Free, no obligation, in English. If your case calls for an amparo we file it in 72 hours for MX$9,900. If an administrative appeal or an annulment suit fits better, we say that instead.
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