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The new judicial criteria on tax refunds and their impact on taxpayers

October 13, 2025 /
Season 3

In this episode of Legal Evolution, we are joined by Juan Carlos Machorro, a partner at our firm, and Karina Robledo and Sarahí López from our tax practice. We discuss a couple of recent Supreme Court rulings that require: (i) if the tax authority rejects a refund on substantive grounds, it must be appealed, unlike previously when the refund could be rectified directly with the Tax Administration Service (SAT); and (ii) that taxpayers must fully comply with the requirements issued by the authority regarding refunds before the authority can issue a second request, which could be arbitrary.

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