Overview
- Primero Empresa Minera must pay MXN 2,868,853,516.57 for 2012 ISR and IETU, including updates, surcharges, and fines, after the judgment was left final.
- The plenary backed Minister Lenia Batres’s project to overturn a February admission by then–court president Norma Piña, granting a Finance Ministry reclamation that led to the case’s dismissal.
- The Court declined the company’s request to delay resolution, noting there is no mechanism in law to postpone while the firm pursues talks with fiscal authorities.
- On October 23, the Court fined the company 70 UMA for an unfounded impediment aimed at stalling the case, a sanction ministers described as a check on procedural tactics.
- The fiscal credit stems from SAT oficio 900-06-04-0000-2019-000773 validated by the TFJA in 2023, with the firm’s separate international arbitration filings noted in prior reporting.