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Mexico’s High Court Backs SAT Fine on Grupo Salinas Unit, Will Review FEMSA Tax Case

The decisions reinforce judicial backing for the tax authority’s power to directly audit subsidiaries under the 2012 fiscal code.

Overview

  • On November 19, the Supreme Court validated a 67,165,827‑peso fine against Nueva Elektra del Milenio for overstating 2012 losses, approving Minister Lenia Batres’s project by a 6–3 vote and revoking a prior amparo.
  • The Court rejected an attempt to exclude Ministers Batres and Yasmín Esquivel from the case and sanctioned Nueva Elektra 300 UMA for bad faith and delay.
  • With this decision, the Court has resolved eight of nine Grupo Salinas matters, confirming credits exceeding 48 billion pesos, while a 621.9 million‑peso Totalplay case remains pending.
  • After first voting 8–1 on November 6 against attraction, the justices voted 6–3 on November 13 to take up FEMSA’s 2,868 million‑peso dispute tied to a 2011 “bono segregable” operation and a previously invalidated 2005 amount.
  • Grupo Salinas denounced the rulings as politically motivated and said it will continue its legal defense, including actions before other national and international fora.