Santamarina Steta

Deadlines to File Amparos Against Unconstitutional Provisions of the SAT Expire: Santamarina y Steta

  • Some have unconstitutional aspects, matter to file protections..
  • Various limitations and rules that are already of fiscal persecution..

Mexico City, February 9, 2022. Mariano Calderón, an expert partner in tax matters at the legal firm Santamarina+Steta announced the first window of opportunity for companies to present amparo against provisions derived from the tax reform 2022 that have unconstitutional aspects. "Various entrepreneurs have expressed a feeling that obligations, restrictions, and supervision are increasing, under an environment of terrorism and fiscal persecution, even when they have traditionally complied with their obligations to the public treasury," he said.

The expert pointed out that the production company has the right to defend itself against unnecessary charges or problems in compliance with unconstitutional tax obligations and that therefore, can be fought through an amparo trial.Among the main provisions susceptible to request protection, Mariano Calderón highlighted a new limitation to deduct bad debts, new rules for the deduction of interest, notices for the sale of shares, and cases of joint and several liabilities. “He worries us about the behavior of the authority, which does not recognize the right of taxpayers to act in good faith. The authority sees them as entry evaders. They have the right to defend themselves,” he concluded. 

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