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Mexico’s Supreme Court Orders First Majestic Subsidiary to Pay 2.87 Billion Pesos in 2012 Tax Case

The unanimous ruling upholds a 2019 transfer-pricing order by the tax authority and rejects the miner’s request to postpone resolution.

Overview

  • The Supreme Court confirmed Primero Empresa Minera must pay 2,868,853,516.57 pesos covering income tax, the former single-rate business tax, updates, surcharges, and fines for fiscal year 2012.
  • Justices approved Minister Lenia Batres’s project, which left intact the validity of SAT’s November 25, 2019 order 900-06-04-0000-2019-000773.
  • The Court granted a challenge from the Finance Ministry and revoked an earlier decision by then-president Norma Piña that had admitted the company’s constitutional appeal.
  • On October 23, the Court fined the company 7,919 pesos for an unfounded bid to recuse Minister Yasmín Esquivel that delayed proceedings.
  • Primero Empresa Minera, the Mexican unit of Canada’s First Majestic Silver, previously pursued international arbitration over tax disputes, and the 2023 administrative tribunal ruling upholding the SAT order now stands.