
The ABCs of when the SAT denies tax solvency without prior proceedings
In Guatemala, tax solvency has become a key factor in the economic life of taxpayers. Although...

“David Erales is an excellent, highly trained professional who is capable of handling complex matters.”
David is a Partner at Consortium Legal – Guatemala with 18 years of experience advising clients in the financial services and fintech, food and beverage, and agribusiness sectors. A specialist in tax, civil, commercial, and intellectual property litigation, he has represented clients before the Superintendence of Tax Administration (SAT) and in high-stakes disputes before Guatemala’s highest courts.
He is widely recognized for his work in extraordinary Cassation appeals before the Supreme Court of Justice and the Civil Chamber, as well as in constitutional actions for amparo and unconstitutionality (both general and case-specific).
In academia, he has been a Tenured Professor at Universidad del Istmo since 2014, teaching Civil and Commercial Procedural Law II and III. Since 2021, he has also taught Administrative Tax Procedural Law and Judicial Tax Procedural Law in the Master’s Program in Tax Advisory at Universidad Rafael Landívar. He is a frequent speaker, panelist, and moderator in specialized forums organized by the Guatemalan Institute of Procedural Law, the Guatemalan Institute of Tax Law, the Guatemalan Institute of Public Accountants and Auditors, C-Educa, among others.
He currently serves as Vice President of the Board of Directors of the Guatemalan Institute of Procedural Law.
Diagonal 6 11-10 zona 10 Edificio Diago6, nivel 10. Oficina 1001


In Guatemala, tax solvency has become a key factor in the economic life of taxpayers. Although...

I- Analysis of the different tax rulings in Guatemala in the period 2023. In Guatemala, court...

In the previous article, I discussed the reasonableness of the complementarity rule between the cassation sub-motives...

Part I In Guatemala, the extraordinary appeal of cassation is processed and resolved by the Supreme...

By: David Erales. In the last 10 years there has been a difference of criteria between...

The Central American region has been characterized by a very dynamic economic, political and social development,...
By: David Erales As a general premise, exports of merchandise are exempt from Value Added Tax,...
By: David Erales Compliance with the banking system in tax matters is regulated in articles 20...
By: David Erales During the administrative procedure, it is advisable for taxpayers to file a claim...