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Previously the fees that company directors charged were given special tax treatment that privilege has now been withdrawn. Now only directors still qualify for a special individual income tax treatment. The SAT has initiated a special tax bureau to deal with multinational companies tax issues, but scrutiny is not only limited to large foreign companies - any kind of FIE is now subject to much more detailed appraisal of tax returns. Foreign companies have been punished for attempting to avoid tax through transfer pricing, with one client of a large accountancy firm already being subject to a considerable fine. But this new approach from the SAT has ramifications beyond simple tax avoidance. Marquis says have been instances where mistakes in tax returns that do not materially affect the amount of tax paid by the company have been punished severely, beyond what we would normally see for such a small infraction. 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