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Supreme Court Revokes Amparo, Confirms 67 Million Peso Tax Credit Against Nueva Elektra

The ruling affirms the tax authority’s power to audit subsidiaries individually.

Overview

  • Mexico’s high court voted 6–3 to overturn a prior amparo, with Loretta Ortiz, Yasmín Esquivel, and Irving Espinosa dissenting.
  • The case stems from a 2018 SAT determination that Nueva Elektra overstated a 2012 fiscal loss, triggering a MXN 67,165,827 credit.
  • Justices rejected recusal bids against Minister Lenia Batres and imposed MXN 33,942 fines on Elektra and Ricardo Salinas Pliego for bad‑faith procedural tactics.
  • The file returns to the 21st Collegiate Administrative Tribunal to issue a new decision recognizing SAT’s authority to audit the subsidiary.
  • Proceedings on related Total Play tax disputes were deferred for further analysis, as Grupo Salinas denounced the decision as politically motivated and pledged further challenges in domestic and international forums.