After the publication of the annual report Productivity, efficiency and non-compliance with income tax (ISR) and value added tax (VAT)which confirms an estimate of evasion of Q47 billion In both taxes during 2025, the tax administration authorities presented details about the findings.
The analysis of the Superintendency of Tax Administration (SAT) is based on the theoretical potential and the observed collection, which is why it estimates a non-compliance rate of 21.36% in VAT and 69.25% in ISR, a tax that, according to the entity, is more complex.
In both taxes, according to the SAT, a reduction is observed compared to 2024; However, the most relevant decrease corresponds to VAT, whose non-compliance rate was reduced by 2.0%.
The amount of Q47 billion, which corresponds to the sum of non-compliance with ISR and VAT, is the gap that the Collection Administration identified in last year’s fiscal year, which was not able to be collected, as well as an estimate of the collection potential.
This exercise has been carried out since 2013 and for this a previously defined and updated methodology is used.
SAT identifies seven causes of tax evasion
Free press He consulted Superintendent Werner Ovalle Ramírez about the elements that have had the most impact on the evasion. In this regard, he explained that the non-compliance study does not intend to make a specific separation or individually quantify the causes that explain the VAT and ISR gap, because the methodology is aimed at measuring the difference between the collection potential of the economy and the collection actually observed.
CONTENT FOR SUBSCRIBERS
Without prejudice to this, from a technical and institutional perspective, some variables that have a relevant impact on tax non-compliance can be pointed out.
In the case of VAT, according to the head of the SAT, because it is an indirect tax associated with consumption and closely linked to the documentation of economic operations, the informal economy constitutes one of the most important factors, especially when sales or services are not invoiced, are not registered or do not fully enter the formal tax compliance circuit.
The study projected that non-compliance with VAT, a tax applied to consumption, was Q14,109 million in 2025, an amount lower than the Q14,669 million in 2024, which reflects a reduction.
Identify six sources of ISR evasion
The position of the tax administrator is that ISR evasion is more complex and, in that case, six trends are identified. The report detected that, in the case of the ISR on lucrative activities, non-compliance amounted to Q32,902 million, Q1,512.34 million more than in 2024, when Q31,389.77 million were identified.
The phenomenon presents a greater diversity of causes due to the structure of the tax, the existence of different regimes and the complexity of certain economic operations, he explained.
Among the causes that may have an impact are underreporting of income, improper use of costs and expenses, arbitration between regimes, tax avoidance, operations between related parties and, above all, aggressive tax planning.
Therefore, according to Ovalle Ramírez, these factors should be understood as general explanatory elements that help interpret the behavior of non-compliance, but not as a quantitative breakdown derived directly from the study.
Plan to reduce non-compliance
There are four actions that will be undertaken, commented Ovalle Ramírez. Reducing tax non-compliance levels is part of the SAT’s priorities within the framework of the Institutional Strategic Plan 2026-2030, aimed at strengthening a more modern, preventive, risk-based tax administration with greater capacity for the use of information.
In this context, the proposed actions combine control, facilitation of compliance, traceability of operations and tax culture.
In the case of VAT, since it is an indirect tax associated with consumption and closely linked to the documentation of economic operations, the informal economy constitutes one of the most important factors, especially when sales or services are not invoiced.
These include the strengthening of risk-based oversight; the expansion of proposed and pre-filled statements; improving controls on the issuance, cancellation and reversal of Electronic Tax Documents; the identification of fraudulent billing patterns; the systematized application of the measures provided for in tax legislation, such as the suspension of VAT affiliation when applicable; and the expansion of information exchanges corresponding to the current fiscal period.
Likewise, the control of sectors, regimes or taxpayers with greater exposure to non-compliance is contemplated, including those that apply tax benefits, exemptions or differentiated treatments, as well as the promotion of tax culture actions, assistance and collaborative compliance.
CONTENT FOR SUBSCRIBERS
Together, these measures seek to strengthen the preventive and corrective capacity of the SAT, increase the perception of risk, facilitate voluntary compliance and reduce the spaces that allow the omission, underdeclaration or improper use of documents, credits, costs, expenses or tax benefits.
SAT: Evasion affects the entire society
Regarding the persistence of this practice and who the potential beneficiaries are, the SAT assures that it has detected a pattern.
“Non-compliance with tax obligations persists due to the combination of structural, economic and behavioral factors that affect the current control capacity, compliance incentives and the way in which some economic agents carry out their activities,” justified the head of the SAT.
Non-compliance generates an undue benefit for those who do not comply, indicated Ovalle Ramírez, because it allows them to operate with a lower tax burden on taxpayers that they do meet their obligations in accordance with the law. “In practice, non-compliance distorts competition, affects the equity of the tax system and places greater relative pressure on those who do comply with the payment of their taxes,” he considered.
Another position is that, although it is usually thought that the main victim is the State or, in particular, the SAT, in reality the impact falls on society as a whole. “Lower collection limits the ability to finance public goods and services, infrastructure, security, health, education and other specific programs for the development of the country,” he stated.
On the other hand, non-compliance weakens the legitimacy of the tax system and damages tax morale, to the extent that taxpayers perceive that some economic agents obtain advantages by staying away from their tax obligations.
Therefore, tax non-compliance should not be understood as a phenomenon that corresponds only to the SAT, but as a problem of equity, unfair competition and sustainability of public financing, with direct effects on the well-being of society and trust among Guatemalans themselves.