On 12 October 2026, the SAT’s legal affairs department published an expert analysis stating that “illegal tax planning” by intermediaries constitutes a direct violation of Article 63 of the Tax Collection and Administration Law. The article clarifies the boundary between legitimate tax advisory services and criminal facilitation, citing the Criminal Law Amendment (XI) provisions on “crimes of providing false certification documents.” Several intermediaries in the exposed cases received prison sentences of three to seven years.
Key Takeaways
- Criminal Threshold Lowered: The analysis confirms that facilitating fictitious transactions or forged contracts for tax benefits meets the “serious circumstances” threshold for criminal prosecution, even if the intermediary does not directly file returns.
- Document Retention Requirements: Intermediaries are reminded to retain work papers for a minimum of ten years under the amended CPA Law, subject to random SAT audits.
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.
Source: Read Official Announcement