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Supreme Court Poised to Rule Against Grupo Salinas in High‑Value Tax Disputes

Draft opinions point to confirmation of the tax credits, signaling SAT collection could proceed.

Overview

  • The SCJN placed seven Elektra and TV Azteca matters on Thursday’s agenda, with projects from five ministers that largely endorse prior rulings.
  • The cases stem from audits linked to the end of the consolidated tax regime and other reviews from 2008–2013, with amounts reported around 48.3 billion pesos and a single Elektra credit of 33.3 billion.
  • Grupo Salinas said it is evaluating a lawsuit against the SAT for alleged doloso silencio administrativo and plans to pursue international remedies before the Inter-American system.
  • The conglomerate said it will pay what is legally correct, rejects what it calls double charges and excessive surcharges, and urged the SAT to quantify the credits for payment.
  • If the Court dismisses the companies’ remedies, the SAT would be positioned to initiate enforcement actions such as embargoes under fiscal law.