This article by Ivan Evair Saldaña originally appeared in the December 19, 2025 edition of La Jornada, Mexico’s premier left wing daily newspaper.
Mexico City. The Supreme Court of Justice of the Nation (SCJN) must resolve at least 69 tax disputes involving billions of pesos in the first quarter of next year, as it is legally required to issue rulings no later than March 1st.
In total, the country’s highest court will close 2025 with 108 pending tax matters, ranging from injunctions to appeals, requests for the power of attraction and requests for reassumption of competence, among others, which must be resolved within six months according to article 17 of the constitution, derived from the judicial reform of 2024.
According to data from the SCJN, these 69 cases were inherited by the new plenary from its previous members; therefore, the deadline to resolve them began to run on September 1st, when the current nine ministers took office.
Among the most significant issues are lawsuits filed by companies against tax credits related to the Manufacturing, Maquiladora and Export Services Industry Program (IMMEX), designed to avoid double taxation on the temporary import of inputs destined for export.
The Tax Administration Service (SAT) reported that between 2019 and 2023, operations were carried out through this program that reached a taxable base of approximately 279 billion pesos, for which the tax authorities failed to collect around 44 billion pesos in value-added tax (VAT).
The Court must clearly define whether there was tax evasion or whether the operations were legal, in order to avoid uncertainty for both companies and the tax authority.
The discussion of this matter has been postponed at least twice during the year: the first time, on February 27, by the previous plenary session, and the second time, on October 1, by the new members, based on a project prepared by Minister Yasmín Esquivel Mossa regarding the contradiction of criteria 8/2025.
Another pending matter is the direct appeal for review 2526/2025, filed by Totalplay, a company owned by Ricardo Salinas Pliego, related to a tax credit of 621.9 million pesos. This is the last tax case involving Grupo Salinas awaiting resolution before the Supreme Court, as last October the full court resolved eight tax disputes totaling over 48 billion pesos, with rulings in favor of the Tax Administration Service (SAT).
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