Historically, in addition to the fact that tax audits were often mandatory, they also had tangible benefits. One of the main ones was that, in the event of an audit by the Tax Administration Service (SAT), the tax authority would first question the external auditor before addressing the taxpayer directly (commonly known as "the sequential audit"). This provided a margin of defense and greater clarity in the audit, allowing companies to correct omissions without direct and immediate exposure to the authority.

However, recent tax reforms have changed the dynamics of this process. Currently, there have been cases where the SAT exercises its review powers directly over the taxpayer, regardless of the existence of a tax ruling. As a result, the benefit of this intermediary role has practically disappeared.

Furthermore, the tax opinion entails an additional burden in terms of both work and costs. Preparing this document requires a detailed audit of the financial statements, which results in increased auditor fees and a greater investment of time for companies.
If we add the fact that, with the 2022 tax reform, the deadline for submitting the tax opinion was brought forward from July 15 to May 15, this represents an additional challenge, not only for auditors but also for taxpayers, since the time to attend audits has been reduced,
but the workload, no.