The SAT just hit you: fine, seizure, restricted seals or 69-B — the complete map of your defenses

Against almost any act of the tax authority there is a defense — but each one has its own door, its own deadline (almost always brutally short) and its own strategy. The most expensive mistake isn't losing a trial: it's letting the deadline for the right remedy run out while attempting the wrong one. This is the map, problem by problem. The links to courts and agencies are in our Resource Center.

The arsenal, from lowest to highest caliber

1. Administrative clarification (aclaración). The express route for obvious errors and minor acts: fines for supposed breaches already cured, notices demanding returns already filed, an incorrect compliance opinion. It's filed through the SAT portal, with no litigation formalities. Cheap and fast — but it does not suspend the deadlines of the formal remedies: if the matter is serious, the clarification runs in parallel, never instead of the defense.

2. Clarification for seal restriction (17-H Bis CFF). When your CSD is temporarily restricted — and with it, your ability to invoice — art. 17-H Bis itself provides a clarification procedure with a vital effect: once the clarification is filed, the authority must let you invoice again on the next business day while it resolves. It is the number-one emergency in the catalog: every day without seals is a day without income. Definitive cancellation (17-H) has its own, heavier procedure.

3. Rebuttal under 69-B. If you are presumed to have issued nonexistent transactions (EFOS, a shell-invoice issuer), you have 15 days (extendable by 5) to bring the proof of materiality. If you are the client (EDOS) of a party on the definitive list, 30 days to prove your transactions were real or to self-correct. These are the shortest and highest-consequence deadlines in the system — and they are won with the file you built beforehand, not the one you improvise in two weeks.

4. Administrative appeal (recurso de revocación). The first formal instance against tax assessments and definitive acts: it's filed with the SAT itself through the buzón tributario (tax mailbox) within the 30 business days following notification. Its two tactical advantages: it does not require securing the tax interest while it's pending (collection halts without tying up your cash flow in a bond) and it lets you introduce additional evidence. Its limit: the authority itself resolves it — the success rate is real but bounded; often its strategic function is to buy time, clean up the file and arrive better armed at the court.

5. Administrative litigation trial (annulment trial). Real litigation, before the Federal Administrative Justice Court (TFJA) — a body independent of the SAT. Deadline: 30 business days from notification (of the original resolution or of the one that denied your appeal). Here, yes: to suspend collection you must secure the tax interest (a surety bond, an administrative seizure, a deposit — each form with a different cost and strategy). There is a summary track for minor matters with abbreviated deadlines and an exclusive-merits remedy to fight substance alone. Realistic duration: from many months to a couple of years — and it's where the big matters are reversed.

6. Amparo. The constitutional route: against the TFJA ruling (direct amparo) or against acts that violate rights directly and imminently — the illegal freezing of accounts is the classic example where an indirect amparo with a stay can release your treasury. General deadline: 15 business days. It is the top floor of the building, not the front door.

The parallel route few use: PRODECON

The Office of the Taxpayer Defense Attorney (PRODECON) is the tax ombudsman — free of charge — with two underused tools: the complaint (queja) (fast institutional pressure against arbitrary acts: accounts frozen without grounds, refunds kicked down the road, abusive verifications) and conclusive agreements (acuerdos conclusivos), the jewel of the catalog: a formal mediation during the audit (before the assessment even exists) that suspends the review's deadlines and lets you negotiate the findings with the authority seated at the table — with a 100% waiver of penalties the first time (art. 69-G CFF). For audits with partly well-founded findings, it is usually a better deal than the best trial.

The problem → remedy map, in brief

Minor fine or administrative error: clarification; if it doesn't succeed and the amount warrants it, the administrative appeal. Determined tax assessment: administrative appeal (no security) → annulment trial (with security) → direct amparo. Seal restriction: 17-H Bis clarification today. 69-B presumption: rebuttal within 15 days with a materiality file. Seizure or freezing of accounts: a combination of emergencies — clarification/PRODECON complaint + trial or amparo with a stay, depending on the defect. Audit under way with findings: a conclusive agreement before it turns into an assessment. And the constant in all of them: the notification date defines everything — record it, count it in business days, and don't let it age even a week.