Tax Law

Tax Litigation

Tax litigation is at the heart of our firm. Our tax controversy team is a leader in Mexico, representing clients in litigation at both the federal and state levels. We have successfully advised numerous clients in a wide range of complex proceedings, including:

  • Tax Audits and Examinations. Representation and defense in connection with actions and requests arising from the exercise of audit and examination powers by the Mexican Tax Administration Service (SAT) and local tax authorities.
  • Administrative Proceedings. Filing and handling administrative appeals before the Mexican Tax Administration Service (SAT), as well as appeals and other legal remedies before local tax authorities.
  • Litigation Before Administrative Courts. Annulment actions and other administrative litigation proceedings before the Federal Court of Administrative Justice and local administrative courts.
  • Tax Disputes in the Mining and Metallurgical Sector. Representation in tax disputes related to the exploration, extraction, processing, and commercialization of minerals, including disputes involving fees, government charges, and other taxes associated with the use and exploitation of natural resources and public assets.
  • Disputes Involving Concessions and Sector-Specific Regulations. Representation in disputes concerning tax obligations arising from concessions and activities subject to specialized regulatory frameworks, including matters involving the interaction between tax laws and the legal framework governing the mining industry.
  • Amparo Proceedings. Representation and defense through indirect and direct amparo proceedings before Federal District Courts and Collegiate Circuit Courts of the Mexican Federal Judiciary, including matters of significant legal importance.
  • Direct Amparo Appeals. Representation in cases of particular legal significance before the Supreme Court of Justice of Mexico, involving appeals for review of direct amparo rulings.
  • Conclusive Agreements. Guidance and representation of taxpayers in proceedings before the Mexican Taxpayer Defense Agency (PRODECON), particularly as a mechanism to prevent or resolve disputes arising from tax audits and examinations.
  • Tax Assessments and Penalties. Defense against tax assessments, fines, and other liabilities arising from complex transactions, including disputes involving the interpretation and application of tax laws and specialized tax regimes.
  • Social Security and Employer Obligation Disputes. Representation of manufacturing companies in disputes with the Mexican Social Security Institute (IMSS) and other administrative authorities, including proceedings involving occupational risk insurance premiums, employer obligations, penalties, and administrative actions that directly affect operational continuity and costs.

Tax Consulting

Committed to staying up-to-date of the latest regulations and developments in tax matters, we provide our clients with thorough study, diligent work, and in-depth investigation to deliver highly specialized solutions tailored to their specific needs. Our focus is always on ensuring strict compliance with the applicable normative framework in fiscal matters.

We offer industry-specific advice tailored to each client’s unique needs, covering both national and international operations and tax structures, including mergers and acquisitions, financings, and more.

Our non-contentious procedures include:

  • Tax Planning and Structuring. Tax analysis prior to the execution of transactions, corporate restructurings, mergers, spin-offs, capital contributions, acquisitions and disposals of shares, and internal reorganizations.
  • Tax Advisory and Compliance. Requests for formal tax rulings and confirmations from tax authorities, tax due diligence, tax refund claims, tax credit offsets, and guidance throughout tax audit and examination processes.
  • International Transactions. Interpretation and application of double taxation treaties, as well as tax advisory services for cross-border transactions.
  • Taxes and Government Charges Related to Natural Resources. Analysis of fees, government charges, and other taxes applicable to activities involving the exploration, extraction, and exploitation of natural resources and public assets.
  • Transfer Pricing. Advisory services and representation in tax audits and examinations involving intercompany transactions and profit allocation among entities within corporate groups.
  • Mining Sector and Regulated Activities. Analysis of fees, government charges, and other taxes applicable to activities involving the exploration, extraction, and exploitation of natural resources and public assets.
  • International Trade and Customs. Tax and customs advisory services for import and export operations, including the implementation, management, and compliance requirements of IMMEX Programs, as well as supply chain security, security matrices, and representation in proceedings before customs authorities.

Recognized Leadership

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